35 III. BECAUSE the chilling effect caused by surveillance in general was explained by Justice Subba Rao in his dissenting judgment in Kharak Singh v State of UP [subsequently approved in Puttaswamy (Privacy)]. Recognising that it is impossible to show actual, tangible harm in the case of surveillance, Justice Subba Rao noted: “The freedom of movement in clause (d) therefore must be a movement in a free country, i.e., in a country where he can do whatever he likes, speak to whomsoever he wants, meet people of his own choice without any apprehension, subject of course to the law of social control. The petitioner under the shadow of surveillance is certainly deprived of this freedom. He can move physically, but he cannot do so freely, for all his activities are watched and noted. The shroud of surveillance cast upon him perforce engender inhibitions in him and he cannot act freely as he would like to do. We would, therefore, hold that the entire Regulation 236 offends also Art. 19(1)(d) of the Constitution.” IV. BECAUSE this doctrine is well-accepted across the world. In NAACP v Alabama (357) US 449 (1958) the Supreme Court of the United States famously struck down compelled disclosure of the membership lists of a civil rights organisation (the NAACP), noting that the knowledge of surveillance would force politically unpopular or dissident individuals and groups into selfcensorship.