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Detailed Analysis of Film Censorship in India and Contemporary Issues

 Detailed Analysis of Film Censorship in India and Contemporary Issues

By- Abhinav Bishnoi* and Suyash Vijayvergiya*

Source:indianfolk

Abstract

This paper aims to see the validity of the censorship laws in India. Indian film censorship is one of most strict in the world. In the country where the law can respect the naked sadhus, Khajuraho and Konark temple art. From the British era onwards, the government has always tried to imposed restriction on the fundamental right of speech and expression which also altogether put effect upon the fundamental right to trade and commerce on the ground of national interest and protecting the public sentiments and international relation. The paper focuses on the case laws and Indian laws which regulate the film and TV shows content and to what extent with the help of real-life examples. It would also try to differentiate between the reasonability of the restriction imposed by the government to date. Also, cover the aspect of the online streaming of shoes and web series regulation and restrictions. The research done for this project is doctrinal in nature.

 

Introduction

Censorship is a process through which the state can put restriction over the content of which the public view. In India, there are very strict laws and regulation related to film censorship. Which as per many film industry people is clearly violative of their fundamental right to speech and expression as per article 19 (1) (a)[1]. So, in India, the government has to see through its Ministry of Telecommunication and Broadcasting that any content in the film been shown is not against the public interest or in order to maintain the public order it does become important for the government to put some restriction on the films and have a pre-censorship process. As in India, there are many sensitive issues which need to be taken care of as India is a very diverse country has seen being getting a lot influenced by the film industry. But the Cinematography Act 1952 which mainly governs the film industry have set up the quasi-judicial body, known as CBFC which act on the sensitive issues of the films and hence gives the certificate.

Though for the online streaming videos there are no particular laws exist in India for the time being but still, Government holds the right or restrict the public from watching certain content again which are against the interest of the country and public order and as well international relation. Under section 79 (3) (B) of the Information and Technology Act 2000, the government has banned the 857 porn sites in India. 

There are a lot of people who says that the content should not be circumscribed because in India there are many intelligent people who know what to read and how to react to it. But at the same time, the government of India is a responsible authority must keep a tab over the content which are sensitive to the society[2]. India being a very diverse place holds many sensitive issues which are to be censored by the government. And talking about the intellectuals in India is that the literacy level of the country is not yet up to the mark and in order to maintain public order there have to be laws governing the films of India because as per the reports Bollywood industry has the highest influence over India due to its large viewers.     

For India to be a modern society there has to be liberalization in the not merely in the economy and social institution s but also in the content we see or read. But indeed, in the later, there is a danger of social unrest in the public. The members selected for the board of CBFC, there has been no criteria set to make any person a part of the board. Therefore, any person can be a CBFC member irrespective of his/her qualification. Like the example of recently held controversy where Mr Chauhan was been made the CBFC chairperson without holding any experience in the film industry[3]. Mr Amol Parekar is one of the leading people who hold his voice against the laws related to the film censorship. He argues that any person who is only speaking the truth on the big screen has to face censorship and the board cut the scenes and restricts him from showing it no matter if it is true in nature. He also argues that online censorship is a very different concept where the person can show whatever they feel like showing in their show. So, actually, there is a lot of lacunas in the laws related to the matter which need to be reconsidered. And the films like, Aligarh University and Udta Punjab and many more have to face the restriction which is as per him is clearly violative of their fundamental right to speech and expression. The homosexuality which the board was considering to be sensitive for the people to react to the same has put down many cuts in the films, though this was based on the true incident still it was against the public interest as per the board so has to face the restriction. And same was the case with the Udta Punjab film, based upon the drug abuse in Punjab had again face the restrictions[4]. 

Shyam Benegal committee was appointed by the Telecommunication and Broadcasting Ministry has given many suggestions including that the CBFC should only be a certification body which gives certificate on the basis of age and maturity and including some restriction: if the films contain anything which is in contravention to section 5B (1) of the Cinematography Act 1952[5]. The certification must be kept within the rights an obligation laid down in the Indian Constitution, parents are informed viewing decision. That the certification should be further broken done into subcategories in order to make easier viewing decision. That the chairman of the board does not act in the day to day functioning of the body. Review of the public reaction and annual government report to be submitted to the government. Total board members should not be more than 9 members excluding the chairman, which each region of the country. And all nine regions have advisory panel comprising of 50% women reservation, who are acquainted with the language of the region. Online submission of the form should be admitted from the film producers or representatives. On basis of a complaint from the government on any film, the chairperson of the board shall reconsider the film certification under the revising committee. The committee is still working on the issues of wildlife and animal welfare under preservation of cruelty to animal act and smoking scenes in the film.       

 

Difference between Film Censorship and Other Form of Media Censorship

So, the difference between the film censorship and other forms of media censorship is quite certain especially in the recent time i.e. we can see different production houses making their own online application and thus because they have their own code of conduct, they do not fall under the ambit of film censorship which is the CBFC. There has been spectacular growth in the internet social media or other website online streaming shows. The people have now the power to write the thing which they think fits as per their understanding on their blogs or social media without any restriction. And in the centre is the independent voice of the people. Public show that they have the courage to voice up against the corruption or any such social ill of the society and they also have the power to influence the public policy[6]. The recent uproar in the country is regarding the control, of the government on internet, they have said that the social media such as Facebook or any other should keep a check upon the content that has been uploaded upon their portal. IT ministry has already issued the notification to such renowned social media companies. Ministers have a complaint to the following ministry for the defamatory remark by the people upon them and hence putting a bar upon the freedom of speech and expression. So, the content should be censored by the authorities. Taking the example of China where approximately 30,000 people are employed by the state only for keeping tab upon the content on the internet. Even in India, there was a notice issued that any defamatory content against any person shall not be forwarded to the next person or will be liable same as if he himself has made the content.

The recent movement that took by Anna Hazare, was formed the basis of an online movement called IAC (India Against Corruption), which has a very active and popular internet presence. And, the government has increased its curb upon the internet restriction by amending the Information and Technology Act in 2008. Also taking into consideration the Mumbai attack in November 2008 has made the government decrypt internet communication especially post-attack. And mainly it was mainly after this Mumbai attack that the status quo of Indian Censorship over the internet freedom got changed and became partly free. Under section 69 of the new amendment act, the police got the power to check any person’s mails, phone calls or any other online transaction. 69 B of the same act says, clause 1, gives the power to the government to make a cybersecurity cell and authorize an agency for monitoring the online traffic data. Clause 2 gives duty to the public and right to the state that in case if such agency asks for the online data of any person then that person is liable to tell. Clause 4 talks regarding the punishment of the same which is fine and imprisonment for a term for 3 years[7]. 

Another case happened with the cartoonist Aseem Trivedi that his online website was been removed from the internet and his domain name and associate services got cancelled as he was found uploading many defamatory photos of the Indian politician. His argument to the court was that how can he be guilty until proven innocent and unless judgement comes forth. Just on the basis of the complaint received by the Mumbai cyber police, his fundamental right got snatched away. In the UPA 2 government, Kapil Sibal once invited a meeting with the social media companies and asked for a pre-censorship of the content uploaded on the internet. Anything which is in violation of any of these issues should be restrained from the internet, Security of the State, Public Order, Decency and Morality, Friendly Relation with the Foreign State, Contempt of Court, Defamation, Incitement to an Offer, Sovereignty and Integrity of India.

Even the media in India does not enjoy separate freedom of the press, like that of the USA. Like Radio News is completely banned in India, with the state-owned All India Radio. Which enjoys a complete monopoly over the business. Hence it is also violative of the fundamental right to trade and commerce under article 19 (1)(g). Vinay Rai case where he filed a petition against the content which hurt the religious sentiment of the public in India. IPC Section 153(B), section 298 is strictly against the promotion of religious enmity but on the other hand, these social media has clearly said that they are not responsible for any such content uploaded by the users. The recent case of the government banning the 857-porn website in India on the ground of decency and morality also face huge criticism.  

 

Film Censorship – A Restriction

According to John Stuart Mill – “A society can develop only by free exchange of ideas.”[8] A person should have the freedom to express his thoughts because freedom of thought is meaningless unless there is a freedom to express those thoughts. Freedom of thought without freedom of expression is like an empty shell. Article 19 of the Universal Declaration of Human rights says that every person has the right to freedom of opinion and expression, and it includes the right to hold opinion without any interference. Article 19 (1) (a) of the Constitution of India guarantees to every citizen fundamental right of freedom of speech and expression. In a democratic society, every citizen has the right to speak as indeed, right to know.[9]  In the case of Romesh Thappar, the Supreme Court said that “Freedom of speech lay at the foundation of all the democratic organization.”[10] Films are one of the most powerful media of expression. Cinema plays a creative role in the dissemination of ideas just like newspaper, books and radio. Influence of cinema on the life of people is incredible and it plays an important role in moulding the habits of youth. It is the most influential form of art. Cinema is for commercial purpose, but it is an effective agent in disseminating ideas. Therefore, it is under the constitutional protection of freedom of speech and expression. In India, Censorship was introduced during British Raj in 1918 when British rulers decided that such legislation should serve their colonial interest. At that time there was no indigenous film industry in India and censorship targeted movies were imported in India from the US. The Britishers wanted to create a rosy picture of west and western ideologies through these movies.[11] Initially, censorship came into the picture to deny Indian audience any access to communalist or socialist ideals reflected in soviet cinema, to ensure that the spirit of freedom and independence do not reach the audience of the colonized country through American film and to prevent the crystallization of nationalist paradigm in the Indian cinema.[12] Post-Independence, the new leaders were against the idea of treating film entertainment in a lenient manner. They associated it with the western influence which they believed that it should at least be checked.  The bureaucrats were all set to adopt a stronger code for film censorship.

In a post-colonial era of film censorship, it has been seen that state use to promote jingoist feature films like ‘Gadar’, ‘Border’ or ‘Sarfarosh’ that incited audience to shout anti – Pakistan slogan, but the maker of the documentary 'Jung aur Aman' had to seek judicial intervention against the CBFC for preaching a rational, pacifist approach.[13]  It was observed that state allowed film like ‘Satya’ which depicted the indiscriminate killing of gangsters at the hand of police but the documentary-like ‘Aakrosh’ was refused certificate on the ground that it depicted violence.[14] In 1964, Chetan Anand made a film named ‘Haqeeqat’ which used to castigate Chinese. This film received great state patronage and popular media support. So, it can be seen that political manipulation of film censorship encompasses not simply a refusal to ‘objectionable’ films but the deliberate promotion of ‘favourable’ films.[15] In 2002, CBFC refused to give certification to a documentary ‘War and Peace’ made by Anand Patwardhan. The committee suggested a list of deletions that included – “(1) Delete the scenes showing Pakistanis burning India's national flags (But nothing was said regarding Indians burning Pakistan's national flag)  (2) Delete the scene showing a Buddhist Dalit leader objecting to India's nuclear tests being conducted on Buddha's birthday and to its codename as 'Buddha smiles' (3) Delete the Dalit song, which says that the killer of Gandhi was a brahmin (4) Delete all references to exposition by Tehelka.com in the film (Of course, objections were not raised regarding the reference to the Bofors scam in the film) (5) Delete part of an interview by an Indian scientist, especially where he says, 'China is India's next enemy' (6) Delete all speeches by politicians, including those by the central ministers and even the prime minister.”[16] This politically motivated censorship was overshadowed because Vijay Anand who was chairman of CBFC retired from his post. Regional censor boards of pre-independence days were dismantled in order to favour CBFC.

Indian Cinematograph Act was introduced in 1952 which formed a premise for the sustenance of pre-censorship of films in post-colonial India. Art. 19(2) and powers under 7th schedule became base for Sec 5B of Indian cinematograph Act. Under this act, if a film has been banned, it imposes restrictions on the film itself, and not simply on the exhibitor who under conditions of his license is forbidden to show the film.[17] In ordinary jurisprudence schedule, 7 is subordinate to Art. 13 which talks about absolute pre-eminence of Fundamental Rights under Art. 19 of the constitution of India and this shows that films should not be censored.[18] Award-winning documentary ‘In memory of Friends’ which is based on violence in Punjab was refused to be shown on television by Doordarshan on the grounds that it will further incite violence.[19] It was held by the court that “Everyone has a fundamental right to form his own opinion on any issue or general concern. He can form and information by any legitimate means.”[20] Bombay high court in one case said that “Censorship in a free society can be tolerated within the narrowest possible confines and strictly within the limits which are contemplated in a constitutional order.”[21] It has been evident from various cases that powers granted to CBFC were misused and it has gone beyond its statutory powers to over-regulate cinema which clearly indicates a violation of the right to freedom of speech and expression. The actions of CBFC in various cases turned out to be highly questionable and the one that has attacked the base of freedom of speech and expression.

 

Judicial Pronouncement and Censorship

In India, many controversies regarding film censorship took place from time to time. Judiciary has played an active role in checking whether censorship is a reasonable restriction to freedom of speech and expression and has accordingly interpreted the censorship laws in the country. There have been various judicial pronouncement with respect to censorship of films.

·        K.A. Abbas Vs. UOI[22]: - The constitutional validity of film censorship regulation was challenged for the first time in this case. The noted filmmaker K.A. Abbas made a movie named ‘A Tale of four cities’ that contrasted between the life of rich and poor, luxury and squalor in four cities i.e. Calcutta, Bombay, Madras and Delhi. He applied for a ‘U’ certificate for unrestricted public exhibition under Indian Cinematograph Act, 1952. The censor board gave ‘A’ certificate to the film restricting it to be watched by adults only. He appeared in the appellate tribunal, but the tribunal gave ‘U’ certificate by ordering some cuts in the movie. Dissatisfied by this he moved to Supreme Court by claiming that censorship itself was a violation of Art 19(1)(a) enshrined in the constitution of India. He raised four arguments:

(1) Censorship itself cannot be tolerated under the constitutional guarantee of the freedom of speech and expression,

(2) Even if it is a legitimate restraint on the freedom, it must be exercised on very definite principles which leave no room for arbitrary action,

(3) There must be a reasonable time limit fixed for the decision for the authorities censoring the film, and

(4) The appeal shall lie to a court or an independent tribunal and not to the Central Government.

The respondents conceded the third and fourth argument, so court focused on the other two arguments. It held the view that “censorship of films, their classification according to the age groups and their suitability for unrestricted exhibition with or without excisions is regarded as a valid exercise of power in the interest of public morality, decency etc. This is not to be construed as necessarily offending the freedom of speech and expression.”[23] In US Supreme court some judge had a view that censorship itself is a violation of freedom of speech and expression. The petitioner tried to bring this view in front of the court, but the court rejected this view by saying that guarantees provided in the US constitution and the Indian Constitution are different. CJ Hidayatullah said that:

“Pre-censorship is but an aspect of censorship and bears the same relationship in quality to the material as censorship after the motion picture has had a run. The only difference is one of the stages at which the state interposes its regulations between the individual and his freedom. Beyond this, there is no vital difference. That censorship is prevalent all the world over in some form or other and pre-censorship also plays a part where motion pictures are involved shows the desirability of censorship in this field. The method changes, the rules are different, and censorship is stricter in some places than in others, but censorship is universal.”[24]

On the question of the reasonableness of Film censorship CJ Hidayatullah said:

“Further it has been almost universally recognised that the treatment of motion pictures must be different from that of other from the instant appeal of the motion picture, its versatility, realism (often surrealism) and its coordination of the visual and aural senses. The art of cameramen, with trick photography, vista vision and three-dimensional representation thrown in, has made the cinema picture more true to life than even the theatre or indeed any other form of representative art. The motion picture is able to stir up emotions more deeply than any other product of art. A person reading a book or other writing or hearing a speech or viewing a painting or sculpture is not so deeply stirred as by seeing a motion picture. Therefore, the treatment of the latter on a different footing is also a valid classification.”[25]

The higher potential of films to influence people and misuse of such a medium has become a ground for the validity of film censorship regulation.

·     S. Rangarajan Vs. P. Jagjivan Ram[26]: - In this case, the decision of Madras High court to revoke the ‘U’ certificate granted to Tamil Film ‘Ore Oru Gramathile’ was challenged before Supreme court. The film criticized the reservation policy in jobs because such policy is based on caste and was unfair to Brahmin. In this movie, it was argued that economic backwardness should be the criterion and not the caste. The High court held that such a movie could incite violence as thousands of people in Tamil Nadu have suffered for centuries. The SC overruled the decision of HC and upheld freedom of speech and expression. The court was of the view that “Freedom of expression which is legitimate and constitutionally protected, cannot be held to ransom by an intolerant group of people.”[27] The court was of the view that criticizing the policies of government openly should not be a ground of restriction to expression. There must be tolerance to others’ views. “Intolerance is as much dangerous to democracy as to the person himself.”[28]

·    Odyssey Communications Private Limited v. Lokvidayan Sanghatana[29]: - In this case, a TV serial ‘Honi Anhonee’ was restrained from being telecasted on the grounds that it would spread superstitions among the public. The Supreme court quashing the order of High court held that right of a citizen to exhibit a film on T.V. will be curtailed only in circumstances set in Art. 19(2) of Constitution.

·    Life Insurance Corporation of India v. Prof. Manubhai D. Shah[30]: - In this case, Doordarshan refused to telecast a documentary film ‘Beyond Genocide’ which was on Bhopal Gas Tragedy. The reason given by Doordarshan was that questions had been raised by political parties and claims for compensation by victims were sub-judice. The court held “Merely because it is critical of the State Government is no reason to deny selection and publication of the film. So also, the pendency of claims for compensation does not render the topic sub-judice so as to shut out the entire film from the community.”[31] It was also held that the state has to prove that benefit of restricting freedom is greater than harm resulting from speech or depiction.

·    Sree Raghavendra Films v. Government of Andhra Pradesh[32]: - In this case, a movie named ‘Bombay’ in its Telugu version was suspended from being telecasted. The reason given was that it may hurt the sentiments of a certain community. The court found that the authorities that suspended movie even didn’t watch the movie. Thus, the impugned order was quashed.

·     Bobby Art International v. Om Pal Singh Hoon[33]: - This case is popularly known as the ‘Bandit Queen case’. The court was of opinion that a film illustrating about consequences of social evil must necessarily show the social evil. A film that brags about a social evil or encourages it is not permissible but a film that shows the message that social evil is evil cannot be made impermissible on the ground that it shows social evil. The court found that the scene depicting Phoolan Devi as naked was not to arouse the lust of cinemagoers but to arouse sympathy by showing that how she was harassed and what social evil existed at that time. This scene helps in explaining the rage of Phoolan Devi and why she became what she was in real life.

·     Prakash Jha Productions v. Union of India[34]: - In this case, State of Andhra Pradesh, Punjab and Uttar Pradesh suspended the screening of the film ‘Aarakshan’ for a specified period. The court held that the movie was seen by expert members of the board and after getting clearance from all members and positive views from two experts the film got the certificate. The state does not have the power to override the board’s decision and propose some deletions in the movie. The court said that it is the duty of the state to maintain law and order and once the board has cleared a film that it can be telecasted in the whole country without any restrains.

·     Bikramjit Singh Vs. UOI[35]: - The petition was filed for banning of film ‘Sarbjit’ because no consent or sanction was taken by respondents from petitioner. The court in this case was of opinion that the film is about the life of a person and is informative in nature. Freedom of speech and expression also includes acquiring information and disseminating it to the public at large. When a film is banned it not only affects the rights of producer or director but also affects the financial and economic aspects of many people. Film making, distribution and screening are essential aspects of the films business, which is guaranteed under Art. 19(1)(g) of Constitution.

·     Phantom Films Pvt. Ltd. v. The Central Board of Film Certification[36]: - In this case, the movie ‘Udta Punjab’ was in controversy due to usage of cuss words, drug trafficking in the State of Punjab. CBFC passed movie with 13 deletions. The writ appeal was filed in Bombay High court and passed movie with ‘A’ certificate and one deletion. The court said, “The power to exercise deletion and cuts should be consistent and in consonance with provisions of the Constitution and directions of the Supreme Court, so that creative freedom is not curtailed.”[37]

 

Findings, Recommendations and Conclusion

The paper has tried to highlight the very vital issue that is ‘seeking offence’, which the political parties or the social institutions try to evoke in the public for their own campaigning is something which needs to be taken care of by the government. Because more than the films it is them who tries to take public order into consideration for their own wellbeing. West where have gone too far and too fast in their film content releasing, India still lags from them but again it is not the comparison between the two. India is more tradition focused, who takes of its trough laws. And it’s not the government in India which rules but the people. It is the western influence that affects the liberation influence against the traditional Indian values. Indian censorship system cannot be wholly be judged on the western system, like for say a kissing scene which is the normal plot of the story has to be cut down because as pee the Indian public it is nor accepted. Cultural behaviour of the public emphasis certain sense of shame in the context of nudity or sex, like pet the Khosla committee. But in India values are changing though on slow pace but they are changing and has come up to become more of a modern state. But still, the advertisement of contraceptive is also something which the government finds immoral and sensuous for the young one and hence restricted to show them only in the night hours. As the Khosla committee has rightly suggested that the Indian society has either must swing towards irresponsible hedonism or towards the shekel Victorian prudery[38]. If the same continues the Indian sub-continent will develop into a modern state which neither wholly forsake the traditional values and nor wholly fetters the incremental advances in the artistic world. And that all is the reasonable restriction clause in the constitution.  The purpose and objective of constitutional freedom of artists, writers, playwrights can be best understood in the words of Justice D.Y. Chandrachud that he said in case of F.A. Picture International v. Central Board of Film Certification:

Artists, writers, playwrights and filmmakers are the eyes and the ears of a free society. They are the veritable lungs of a free society because the power of their medium imparts a breath of fresh air into the drudgery of daily existence. Their right to communicate ideas in a medium of their choosing is as fundamental as the right of any other citizen to speak. Our constitutional democracy guarantees the right of free speech and that right is not conditional upon the expression of views which may be palatable to mainstream thought. Dissent is the quintessence of democracy. Hence, those who express views which are critical of prevailing social reality have a valued position in the constitutional order. History tells us that dissent in all walks of life contributes to the evolution of society. Those who question unquestioned assumptions contribute to the alteration of social norms. Democracy is founded upon respect for their courage. Any attempt by the State to clamp down on the free expression of opinion must hence be frowned upon.”[39]

Also read -  No copyright issue with the film 'Lootcase' : Delhi HC



* III Year, B.A.LL.B(Hons), Institute of Law, Nirma University.

* III Year, B.A.LL.B(Hons), Institute of Law, Nirma University.

[1] •Indian Constitutional Law (eighth edition) by M P Jain, Lexis Nexis

[2] •Censorship in South Asia- cultural regulation from sedition to seduction by Raminder Kaur and William Mazzarella.

[3] •Balsekar, Ameya. “Seeking Offense: Censorship as Strategy in Indian Party Politics.” Comparative Politics, vol. 46, no. 2, 2014, pp. 191–208. JSTOR, www.jstor.org/stable/43664098.

[4] •Someswar Bhowmik. “Politics of Film Censorship: Limits of Tolerance.” Economic and Political Weekly, vol. 37, no. 35, 2002, pp. 3574–3577. JSTOR, www.jstor.org/stable/4412538.

[5] •Someswar Bhowmik. “From Coercion to Power Relations: Film Censorship in Post-Colonial India.” Economic and Political Weekly, vol. 38, no. 30, 2003, pp. 3148–3152. JSTOR, www.jstor.org/stable/4413826.

[6] •Baskaran, S. T. “FILM CENSORSHIP AND POLITICAL CENSORSHIP IN BRITISH INDIA: 1914-1945.” Proceedings of the Indian History Congress, vol. 36, 1975, pp. 493–510. JSTOR, www.jstor.org/stable/44138872.

[7] •Boyd, Bruce Michael. “FILM CENSORSHIP IN INDIA: A ‘REASONABLE RESTRICTION’ ON FREEDOM OF SPEECH AND EXPRESSION.” Journal of the Indian Law Institute, vol. 14, no. 4, 1972, pp. 501–561. JSTOR, www.jstor.org/stable/43950156.

[8] John Stuart Mill, On Liberty (1947) 61.

[9] Constitutional Dimensions of Film Censorship, http://shodhganga.inflibnet.ac.in/bitstream/10603/186548/6/07_chapter%202.pdf, 1 March 2019.

[10] Romesh Thappar vs. State of Madras (1950) SCR 594.

[11] Someswar Bhowmik, From Coercion to Power Relations: Film Censorship in Post-Colonial India,Economic and Political Weekly, vol 38, No.30 (Jul 26 – 1 Aug 2003), pp 3148-3152

[12] Ibid

[13] Ibid

[14] Ibid

[15] Ibid

[16]  Someswar Bhowmik, Politics of Film Censorship: Limits of Tolerance, Economic and Political Weekly, Vol. 37, No. 35 (Aug. 31 - Sep. 6, 2002), pp. 3574 – 3577.

[17] Ibid

[18] Ibid

[19] Constitutional Dimensions of Film Censorship, supra note 2, 60

[20] Anand Patwardhan vs UOI (1997), AIR BOM 25,32.

[21] F.A. picture International Ltd. Vs. Central Board of Film Certification (2005) AIR BOM 125

[22] K.A. Abbas Vs. UOI (1971) AIR SC 481

[23] Ibid

[24] Ibid

[25] Ibid

[26] S.Rangarajan Vs. P. Jagjivan Ram, (1989) 2 SCC 574.

[27] Ibid.

[28] Ibid.

[29] Odyssey Communications Private Limited v. Lokvidayan Sanghatana (1988) AIR SC 1642

[30] Life Insurance Corporation of India v. Prof. Manubhai D. Shah (1993) AIR SC 171

[31] Ibid

[32] Sree Raghavendra Films v. Government of Andhra Pradesh (1995) 2 ALD 81

[33] Bobby Art International v. Om Pal Singh Hoon (1996) 4 SCC 1 

[34] Prakash Jha Productions v. Union of India (2011) 8 SCC 372

[35] Bikramjit Singh Vs. UOI, CWP No. 9417 of 2016 (Punjab & Haryana High Court).

[36] Phantom Films Pvt. Ltd. v. The Central Board of Film Certification, Writ Petition (L) No. 1529/2016.

[37] Ibid

[38] •Hilton, R. H. “Censorship in India.” Past & Present, no. 77, 1977, pp. 142–142. JSTOR, www.jstor.org/stable/650390.

[39] F.A. picture International Ltd. Vs. Central Board of Film Certification (2005) AIR BOM 125

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