"On reading the publication effected, which led to registration of this crime, as extracted hereinabove, it could be gathered that necessary inputs to disclose the identity of the victim in Crime No.297/2017 [actress assault case], alleging commission of offence under Section 376 [rape] of the IPC, were published," the Court said in its order.

In 2017, the survivor-actress was allegedly abducted and sexually assaulted in a moving vehicle by multiple individuals, reportedly orchestrated by Malayalam cine actor Dileep. The trial is currently ongoing before the Ernakulam District and Sessions Court.

Fr. Joseph Kuzhinjalil and Fr. Boby Alex, the printer, publisher, and former Chief Editor of Rashtra Deepika Publications, were accused of disclosing the actress's identity in the December 20, 2017 edition of the Rashtra Deepika Evening Daily. They sought to have the proceedings against them quashed, claiming that the publication did not reveal any details that could directly or indirectly identify the actress.

However, the Additional Director General of Prosecution (ADGP) argued that while the actress's name was not explicitly mentioned, the report, when read in full, made her identity apparent. The High Court reviewed the report and agreed with the ADGP's assessment.

"Going by the relevant portion of the publication, though the same, in no way, disclosed the name of the victim to the reader of the news, but necessary inputs to identify the victim...would give indication to the identity of the victim," the Court noted.

The Court also noted that the elements required to constitute an offence under Section 228A(1) of the IPC encompass not only the printing or publishing of the survivor's name but also the publication of "any matter which may make known the identity" of the survivor or victim.