Voices. Verdicts. Vision

Voices. Verdicts. Vision

SC Dismisses Appeal For Certification of the Movie “Masoom Kaatil” Declares it Too Violent for Public Exhibition

Shyam Bharteey Vs Central Board of Film Certification Regional Officer Delhi & Anr [Order September 10,2025]

Movie Certification Case

The High Court of Delhi on September 10, 2025 dismissed an appeal which challenged the refusal of film certification of the movie “Masoom Kaatil” by the Respondent CBFC (Central Board of FIlm Certification) under Section 5C of the CInematograph Act, 1955. The rejection of the appeal was mainly to the showcasing of extreme gore, animal and human cruelty and lawlessness.

The Appellant (filmmaker) had applied for the certification of his movie on 09.08.22 by paying a requisite fee of Rs. 23,800/- along with the application. The film’s subject matter was then examined by the Examination Committee who refused to register the film by a letter dated 24.08.22. A Revision Committee consisting of five members shortly sat to review the film on 08.09.22 rejected enlisting it in CBFC again because the film-

“(i) justified vigilantism

(ii) was communal in its portrayal

(iii) was full of gruesome violence, killings, human cannibalism, expletives

(iv)showed extreme violence on animals, communal and cast remarks

(v)denigrated religions likely to incite commission of violence

(vi) and depicted school teenagers involved in violence and anti-social activities.” thereby violating the 1991 Certification Guidelines.

The Appellant contested that he was charged twice to apply for the certification not mandated under any law or rule. He further submitted that the Revising Committee were not paying attention while they were reviewing the movie. The Appellants in appeal to CBFC Delhi also mentioned how the movie was meant to be emotional and thought provoking on animal cruelty. The Respondents countered this by stating that the certification fee is fixed by the competent authority, not by the CBFC itself, and emphasized that every film seeking public exhibition must strictly comply with the prescribed guidelines.

The Court observed that the protagonists in the film were school-going minors who glorified lawlessness and gore without coercion negatively impacting social values, brutalizing minds and normalising lawlessness.;violating the Certification Guidelines of 1991 as mentioned by the Respondents. It also observed that it hurt religious sentiments through caste based remarks which promoted disharmony as displayed in the Youtube trailer of the movie. Cases of S. Rangarajan v. P Jagjivan Ram 1989 2 SCC 547 and Raj Kapoor v. Laxman (1980) 2 SCC 175 were cited to analyse the role of certification of films under the Act of 1952 so as to prevent any anti-social impact on the public. The Court after taking account of all the above factors saw no reason to interfere in the jurisdiction of the Examining Committee and the Review Committee and dismissed the appeal accordingly.


Appearances:

For the Petitioner/Appellant: Shyam Bharteey, Advocate for JD-1

For the Respondents (CBFC): Mr. Ripudaman Bhardwaj, CGSC Mr. Amit Kumar Rana, Advocates for JD-2

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Shyam Bharteey Vs Central Board of Film Certification Regional Officer Delhi & Anr

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