The Reel Vs The Rule: To What Extent Is Censorship In Indian Cinema Justified?
- IJLLR Journal
- Dec 10, 2025
- 2 min read
Updated: Dec 11, 2025
Saswata Chowdhury, Student, Xavier Law School, St Xavier’s University, Kolkata
ABSTRACT
Cinema acts as a powerful and controlling phenomenon in the vast dynamics of the Indian society. Censorship of Indian cinema often tends to oscillate between the provision of constitutional rights and the State’s duty to safeguard public morality, order, and decency. Article 19(1)(a) of the Indian Constitution guarantees freedom of speech and expression, but Article 19(2) of the same empowers the State to impose “reasonable restrictions” as and when it deems fit.
This research paper critically analyses landmark Indian judicial decisions on film censorship, including K.A. Abbas v Union of India (1970), S. Rangarajan v P. Jagjivan Ram (1989), Mahesh Bhatt v Union of India (2009), Qurban Ali v CBFC (2023), Mohammed Sami Ullah Qureshi v Government of Telangana (2022), and Manohar Lal Sharma v Sanjay Leela Bhansali (2017). This research paper provides a substantial amount of factual information, analysis of the relevant statutes and judicial reasoning as well as critical evaluation of each case discussing whether censorship was justified in that situation or not. This research comes to conclude that while certain instances of imposition of censorship were justifiable under Article 19(2) and the Cinematograph Act, 1952, the predominant trend seen in censorship of Indian Cinema is that there is suppression of democratic freedom instead of the addressal of legitimate societal concerns.
This paper charts the development of censorship in Indian cinema spanning from the 1970s to the present times. It analyses statutory frameworks and describes the practical interactions between Articles 19(1)(a) and 19(2). It assesses the necessity and proportionality of restrictions by means of a case- by-case analysis. Beyond doctrinal analysis, this research evaluates the societal role of films in influencing representation, public debate, and democratic accountability. This research investigates the impact of certification procedures on underrepresented and marginalized voices; and monitors new issues brought about by regional films, streaming services, and international distribution of Indian films. This research argues the case for a change, from content-control to context-sensitive regulation, that prioritizes limited, moralistic editing, age-ratings, and transparency as a response to observable threats to social order.
Keywords: Indian Cinema, Film Censorship, Freedom of Speech, Central Board of Film Certification (CBFC), Judicial Review, Pre-censorship, Artistic Expression.
