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Issues: Whether a one-sheet poster/handbill was a "paper" within Section 3 of the Press and Registration of Books Act, 1867 so as to require the printer's name to be printed on it, and whether omission to do so attracted liability under Section 12.
Analysis: The expression "paper" was not defined in the Act, though "newspaper" was separately defined and the Act's title, preamble and the heading of the relevant part showed that the legislation was directed primarily to printing presses and periodicals containing news. The Court considered the wider reading that would treat every printed piece of paper as covered and found that construction too broad and productive of absurd results. It accepted the view that the statutory phrase could not be stretched to include a poster of the kind in question, which did not contain news and was not analogous to a book, newspaper or pamphlet. The absence of any specific definition of "paper printed" left a gap in the Act.
Conclusion: The poster was not a "paper" within Section 3, the omission to print the printer's name did not contravene the Act, and the conviction under Section 12 could not stand.