television channels, and 50 radio stations. The Media Ownership Monitor (MOM) of Verité Research, in 2018, examined ownership structures across 46 media outlets, spanning print, broadcast, and online platforms. While identifying ownership of news websites can be challenging, MOM traced ownership of at least 44 outlets to 23 families and individuals (Media Ownership Monitor Sri Lanka 2018, n.d.). State-owned media holds significant sway in the industry, with the Ministry of Mass Media overseeing key outlets such as the Sri Lanka Broadcasting Corporation, Rupavahini Corporation, Independent Television Network, and Associated Newspapers of Ceylon Limited. However, these outlets, encompassing print, radio, television, and online platforms, lack substantial editorial independence (Sri Lanka | RSF, n.d.). Further, the ownership concentration is pronounced, with 23 individuals owning 44 leading media outlets. Predominantly privately owned, the top four owners in print, television, and radio exert significant influence, contributing to audience concentration. State-owned media feature prominently among the top four owners in print and television, with State ownership extending across all four mediums in 2017. Further, the State is the sole regulatory body for the sector. Political affiliations are apparent in media outlets, particularly in print, where at least six companies have direct ties to individuals in political office or their associates (Media Ownership Monitor Sri Lanka 2018, n.d.). Over the last twenty years, a minimum of 44 media members have been assassinated or declared as missing persons (Sri Lanka | RSF, n.d.). Despite the cessation of journalist killings post-2015, no perpetrators have been brought to justice (RSF, FPU and the CPJ Create the People’s Tribunal to Indict Governments, Seek Justice for Murdered Journalists, 2017). Numerous journalists have endured arrests, detentions, assaults, threats, intimidation, and harassment under various administrations. Media organisations have been targeted to the level of dysfunction through arson attacks and legal battles, with notable instances including the English weekend paper Sunday Leader and Tamil daily newspaper Uthayan, both known for their strong criticisms of the Government (Reporters Without Borders, 2013). This pattern of suppressing the media continues even today, as evidenced by the treatment of journalists like Tharindu Jayawardena and networks like MTV for their coverage of protests and movements of dissent (Fernando, 2022). The assassinations of Lasantha Wickrematunge (Butler, 2022), Mylvagnanam Nimalaranjan (Lawson, 2000) and the disappearance of Prageeth Ekneligoda (Dhawan, 2024) are some prolific cases of media suppression in Sri Lanka. LAWS AND CASES Notably, in the case of Kurukulasuriya and Jayasekara v Sri Lanka Rupavahini Corporation and Others, the judges held that “the media is not restrained from publicising or broadcasting criticism”, and that such criticism is legitimate, thereby, expanding the freedom of expression to publications through the media. Section 5 of the Profane Publications Act No. 41 of 1958 makes it an offence to publish content insulting religious belief, or ridiculing any figure, picture, emblem, device or other thing associated with, or sacred to the followers of any religion. Interestingly, the term “profane publication” is defined to be any newspaper, book, film, picture or other visible representation that insults a - 12 -