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The right to freedom in Article 19 guarantees the Freedom of speech and expression , as one of its six freedoms. This act was brought about in the backdrop of a series of murders of Arya Samaj leaders who polemicized against Islam. This started in with the murder of Pandit Lekhram by a Muslim because he had written a book criticizing Islam. It was imposed by the British on the Hindus in order to shield Islam from criticism". Precedence to this law started even before this as in a case against Arya Samaj preacher Dharm Bir in , ten Muslims were sentenced for rioting, but Dharm Bir was also charged under section for "using offensive phrases and gestures … with the deliberate intention of wounding the religious feelings" of another community; and under Section , for "wantonly provoking the riot which subsequently occurred" and "a judge was brought in who could assure conviction".