100 YEARS OF FILM CENSORSHIP IN INDIA

ABSTRACT-

The relationship between Indian film and censorship has now been a century old they share a
ferocious battle with one another in term of there hostility and antagonist .The history dates back
to 1918 when the colonial ruler anticipated the wide spread impact that the a medium like the
film industry might have on the masses at could be used for various purposes like uniting the
nation , infusion of nationalism promoting anti – incumbency felling and other such purposes
which wasn‘t desire at all by the colonial govt at that point of time .After that India got
independence yet unfortunately there was insignificant change in the attitude of the government
toward the film industry . More often than not censorship continued to perform the same function
as it was envisioned by the colonial rulers which is to curb the voice of both individual and
masses if they spoke against the authority or any social taboo in their perspective .

There had been various such incident where action of censorship have nothing been rather than a
display of mere political power .Various judicial pronouncements , writing and opinion of
learned persons and veteran film personalities have spoken against this practice , which recently
reached new height of arbitrariness and unreasonableness . With the advent of time there has
been the introduction of the Cinematograph ( Amendment ) Bill 2018 which despite a few of it‘s
drawbacks still has hope for betterment in the system of censorship and granting more individual
autonomy and freedom to film makers .

This long article would try to retrace this 100 year old journey of the censorship in Indian film
With special reference to the statute enacted judicial decision pronounced and a analysis of
recent amendment bill brought before the parliament .
INTRODUCTION

Media, which has been derived from the late 19th century Latin word, membrane basically stands
for ―middle layer‖ or ―sheath‖, as it provides for an interconnected medium or layer, which helps
to dissipate differences and transmit any form of information or art or purely commercial
knowledge to its‘ various stakeholders from a single source or from a collective compose of
various sources.

One of the main pillars of this system is basically cinema-which is the transgression of an early
20th century French term cinema - meaning a hall. As the term itself suggests a state of
collective existence, we definitely cannot ignore the paramount influence and stronghold that this
form of media possess on the society. So, this would held up as a pivot around which the article
would revolve, focusing on the suitability and applicability of the recently developed The
Cinematograph (Amendment) Bill, 2018 and its‘ glaring positivity and positivity.

Cinema, during its ongoing stay in India, has seen a varied history of interference- be it in the
form of censorship or withdrawal, and because of varied reasons ranging from political
animosity, threat of mob violence or appeasement of a particular section of a society.

But, one thing is being certain- which is basically the arbitrariness of such decisions (more often
than not) and the cascading effect that they possessed on the nobility of the ingenious work of an
entire industry, ranging from directors to spot-boy.

With the advent of the Bill itself, there has been a lot of speculation-gazing out a ray of hope for
the entire film industry as a whole- but is it really a panacea or merely a superficial eyewash- to
investigate that would be the sole aim of this article.

DEVELOPMENT OF FILM CENSORSHIP IN INDIA

Censorship is a term whose meaning has not been explicitly expressed under any statute or any
judicial pronouncements. But, if we refer to the Black‘s Law Dictionary 1, it states that

―These are the restrictions on publication and the presentation of books, plays, films etc. to the
public.”.

1
Pg 22,Black's Law Dictionary, Sixth Edition, Centennial Edition, 1891-1991
As we gauge deep into the meaning of this term, on the face of it, we find three essentials-

1. Publication and presentation

2. Books, films, plays etc.- which can be termed as forms of ‗media‘.
3. To the public.

So, it is evident censorship is made only for such issues which when published or brought into
the notice of the public, or a significant portion of the population, is going to affect them in an
undesired manner; more often than not compelling an intervention of an authoritative force-in
the form of Government and such other of its‘ subsidiary enforcement agencies.

Now, focusing on the main essential, which is basically the idea and concept of the term media-
and discovering its‘ various underlying contours and facets.

The term ‗media‘ had been defined by the Orissa High Court in the case of Sudarsan Swain and
Ors. vs. Jagannath Routh and Ors.2 as an intermediate vendor which not only conveys the ideas
of the original source, but also adds some new meaning on it- acting within a scope of
reasonableness.

As evident from the aforesaid opinion of the Hon‘ble Court, media has been treated as a ‗vendor‘
over here- as if it tries to sell something. This notion of media validates the commercial aspect of
the term media- in the form of books, music, films earning huge financial resources at their
disposal, and serving the interests of many. But, this is just one aspect of the term ‗media‘- it has
several other broad aspects at his disposals

But before discussing them, let us narrow down and focus our discussion on the most widespread
and prevalent form of media affecting a layman‘s life-which is ‗movie‘.

To begin with, this term itself in India stands as a misnomer; the Allahabad High Court in the
case of Jafar and Ors. etc. vs. State of U.P. and Ors.3 had held that

“The dictionary meaning of 'cinema' has to be taken into consideration. According to it, cinema
is a motion picture theatre; motion picture industry; the art or technique of making motion
pictures. According to Chambers Twentieth Century Dictionary, cinema is a building in which
2
AIR 1974 Ori 190
3
U.P 2010 (2) ADJ 59
photographs or pictures are shown. The word 'cinema' is an abbreviated form of cinematograph
which, in its ordinary signification, includes a film exhibition. In common parlance a cinema is
equated to a film or movie”.

So, a cinema is basically a structure – a building made of wood, bricks and straw; without any
sensation of creation , logic or emotion in it, unlike any other form of media like book or music,
and it is a prevalent misnomer in the Indian context to call ‗cinema‘ as a form of media-it is only
a licensed legal manifestation which through itself allows the ‗actual‘ form of media i.e. film to
manifest itself to others. Thus, we can state that cinema is basically a ―medium of media‖- it is
the source though which media, another source of communication of ideas, experience, incidents
and feelings comes through.

Now, focusing on the central idea of ―films‖, which is the form of media that would have to be
dealt in detail in this article, we must first look at a judicial pronouncement that has described the
meaning of the word ‗film‘. In the case of Excellent Gravure Industries vs. State of Assam and
Others4, the Guwahati High Court had held that, ―A story, episode, etc. on film with the illusion
of movement or the entire film industry, can even be referred as film‖.

This opinion itself suggests that the word film is both ―conclusive‖ and ―individualistic‖ in its‘
nature- at times, it can refer only to a single episode, and at other times, it may refer to an entire
industry in itself!

Coming back to censorship, the act of censorship falls under no natural principal of justice 5 , nor
it can be argued as a sine qua non function of the Government. Then the question arises, what is
the rationale behind this act, and why this act is given so much importance in our country (we
would be talking about other countries later), as evident from the numerous incidents of
censorship arousing public interest, both in the present and the past?

The answer to this question lies in the long history of colonial subjugation and dominance that
we bear; and to the fact that British used their common law in our country more often than not as
a double edged sword - the same law of censorship which could have been used to achieve
public good and to attain concrete public purposes, was to be used in India to crush public

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2013(2)GLD336 (Gau)
5
Justice ,equity and good conscience
opinion and anti-British propagation of media, and these were the objectives that came into play
behind enactment of the Cinematograph Act,1918.

As we know, in our country, the British had always opted for codification; be it of criminal
matters (IPC, 1860), or civil matters (CPC, 1908) or even contract law (Contract Act, 1872) , and
for various reasons, like that of providing uniformity among judges, and to avoid conflicts
among plethora of communal laws, arising from multiplicity of customs and traditions, at times
contradicting with one another.

Hence, in our country, there was the enactment of the Cinematograph Act,1918, to regulate or in
technical terms, to censor the film industry of the country. But, there was no use of the term
‗censorship‘ in the act, rather the term ‗certification‘ was used. At this juncture, if we try to draw
a distinction between the two, we may say that censorship restricts the publication of a particular
form of media for particular people at particular places, but certification permits its‘ publication
for particular people at particular places. So, where censorship can be deemed out to be an in and
out negative term, certification is sometimes explained as an act done by the Government or an
authoritative force for the welfare of the masses by categorizing which content is suitable for
whom and which is not.

The Act broadly categorized the films into two sections- the ‗U‘ or the universal section, and the
‗A‘ section, which gave the film a restricted screening for only the adult people. Also, the film
provided for restriction of screening of films for the entire public, at the order of the State
Government or the District Magistrate or the Commissioner of police, for the reason that it might
cause ‗breach of peach‘. It became a tool in the hands of the colonial rulers, to quash films that
would be adverse to their interest. But, at that time, although there had been a slight tendency to
infuse patriotism in the masses through the medium of film, as evident from movies like Ananda
Math (1952), Natir Puja (1921), but this attempts had always been overshadowed at that period
by movements of non-violence and boycott movements , and fortunately, much of the movies
didn‘t fall under the rage of the Government ,and no significant incident of censorship can be
recalled from that time, which attracted nationwide interest. Also, this act made it mandatory for
all ‗video houses‘ (cinemas as known back then) to be licensed, which helped it for the
Government to keep a track of all kinds of movies which were being displayed, and also the
modern day concept of ‗licensing‘ tracks back its‘ history from this statute itself. Furthermore,
this Act was not applicable in the state of Jammu and Kashmir, which also shows that the statute
respected the autonomy of this particular state, due to its‘ inherent conditions which are different
from the rest of the country, and which is respected even nowadays.

THE ACT OF 1952 – INDEPENDENT OR COLONIAL IN VIEW

After the independence, the aforesaid statute had been repealed, and the Government of India
enacted The Cinematograph Act,1952.

Well, the significant changes that it brought from the previous repealed statute are:

 It enacted a permanent statutory body known as the ―Central Board for Film
Certification‖ or CBFC.
 It created four categories of certification in place of the earlier two.
 It provided clear cut guidelines regarding the certification/censorship of films, and didn‘t
base them solely on grounds of ‗breach of privacy‘.
 It didn‘t exempt Jammu and Kashmir from the regime of censorship.
 It held that refusing to grant a certificate is part of certification itself, and cannot be
treated as an exception to it.

The Cinematograph Act,1952 is divided into four parts. The first part deals with preliminary-
providing with the short title, coming into force of the Act, and the various definitions of words
as used in the Act. The following definitions, as provided in the Act, can be summed up as
follows:

1. ‗Adult‘ means a person whose age is eighteen years or more.

2. ―Board‖ means the Board of Film Certification constituted by the Central Government
under section 3.
3. ―Certificate‖ means the certificate granted by the Board under section 5A of the Act.
4. ―Cinematograph‖ includes any apparatus for the representation of moving pictures or
series of pictures.
5. ―District magistrate‖, in relation to a presidency-town, means the commissioner of
 Police.
6. ―Film‖ means a cinematograph film.
7. ― Place‖ includes a house, building, tent and any description of transport, whether by sea,
land or air.
8. ―Prescribed‖ means prescribed by rules made under this Act.
9. ―Regional officer‖ means a regional officer appointed by the Central Government .
10. ―Tribunal‖ means the Appellate Tribunal constituted under section 5D.

Moving onto the next part, which is the most important part of the Act, that deals with
certification of films. It broadly, on the face of it, categories movies into five types-

1. Those films which cannot be certified at all

2. Those films that would get a ‗U‘ certificate, being fit for the entire masses, without any
restriction on screening
3. Those films who would get a ‗U/A‘ certificate, which children below the age of 12 can
watch only with the consent of their children.
4. Those films that would get a ‗A‘ certificate, being fit for screening only for adult
citizens
5. Those films that would get a ‗S‘, which would be available for screening by only a
particular section of the society.

The third part of the Act, deals with regulation of means of exhibition of cinematographs in
India. It granted that the licensed cinema owners might be penalized by means of fines or even
cancellation of their licenses. It also granted power to the police personnel as involved by the
State Government to take appropriate action as in certain situations, to prohibit the screening of
certain films.

The last section of the Act deals with repealed status of the the Cinematograph Act,1918 and
declared all such provisions of the previous Act in contradiction with the provision of the present
Act would stand repealed.
After getting an overview of the entire Act, we must contest about the idea that this Act could
not free itself from the shackles of colonial rules, and even though the Act which was enacted by
the British had the excuse (which did appear just to a few) to curb anti-Government movements
and to regulate and ensure proper licensing of the video halls, but the intention of the Indian
Government behind the enactment of this statute really remained obscure- maybe the only
possible could be the tendency to follow on colonial footsteps, and to adopt whatever present in
their system, but with some slight modifications, which ,more often than not appeared
insignificant to the common parlance.

The Act creates or at least tries to create a regime of pre-censorship — or, as explained in
technical terms, a regime that can be called as one of ―prior restraint‖. Before a film can be
released or deemed to be ―fit enough‖ for public viewing, it must be cleared by the CBFC. The
board is tasked with ensuring that the content of the film does not fall into any of the categories
of ―reasonable restrictions upon free speech‖ that are set out under Article 19(2) of the
Constitution of India. However, Article 19(2), consists of barely a set of nothing more than
abstract phrases such as ―public order‖, and ―decency or morality‖. To aid the CBFC in its task,
the Central Government is authorized to frame a few concrete guidelines from time to time.
These guidelines have been changed from at times, and at present lists a lot of things, some of
which might be listed down as ―dual meaning words as obviously cater to baser instincts are not
allowed‖, ―visuals or words which promote communal, obscurantist, anti-scientific and anti-
national attitudes are not presented‖, and ―human sensibilities are not offended by vulgarity,
obscenity or depravity.‖

One glance at these ―Guidelines‖ should be enough to establish that they not only allow, but
positively invite, arbitrary censorial action. Instead of clarifying and cabining the scope of
discretion under Article 19(2), they expand it, creating a broad and vague field within which the
CBFC can operate.

In order to clarify upon this point, let us glance through the particular sections of the Act in itself
which looked ambiguous and which, as stated earlier, not only allowed but positively allowed
arbitrary censorial action.
 1. Section 4(1)(iii) – This is the section that can be said as to introduce the concept of
‗censorship‘ as it grants the authority to the board to exercise its‘ power over the
filmmakers to make such ‗excisions‘ or ‗modifications‘ to get a particular certificate or at
times to get a certificate even.
2. Section 5 (B) (2)- It grants direct power to the Central Government, which can be easily
misused in the absence of any concrete safeguard to recommend changes in the film or
stop the screening of a film as per its discretion for public good. This sounds the colonial
regime, granting a clear upper hand to the Central Government, giving them a chance to
misuse authority.
3. Section 6- The Central Government may upon its‘ own discretion cancel the certification
of a film, suspend the screening and call for the proceedings of the particular film, and
grant certificate only when satisfied that the film has no element of potential threat to
public order.
4. Section 13- The district magistrate can also suspend the screening of a movie, at his/her
own discretion, simply on the grounds of maintenance of public order, and naturally this
section provides for a lot of power at the disposal of the district magistrate which may be
used arbitrarily.
5. Section 17- This section provides for power to exempt of the Central Government of
certain films from any restrictions or certification process involved, giving rise to a
chance of political and personal favourism by the Central Government.
6. Section 12 (4)- It gives central Government the opportunity to issue new guidelines from
time to time about imposing restrictions on the certification of films, and the grounds on
which guidelines may be issued can appear to be ague and uncertain, easily manipulated
by the Central Government.
7. Section 8- Also, it states that the Central government would appoint the CBFC and its‘
chairman, and this clearly shows that if the Government controls everything of the board,
then definitely the board would be biased in favour of the Government.

But, despite all this, there lies a section which is highly commendable, which can be said as the
section which is the key to the escape for the film makers, exhibitors and distributors of the film,
and it can be stated as:
 1. Section 5(F) – highly commendable in nature, as it grants that no film makers or cinema
hall owners shall be subject to any course of action under obscenity for any of the films
certified under any category given above or refused to even certify

So, presence of the aforesaid sections clearly depicts one thing- that the motive which the British
had in their minds while enacting the first Cinematograph Act,1918 i.e. to curb anti-Government
views at the arbitrary discretion of the Government, is the same motive that drove the Indian
Government to enact the Cinematograph Act,1952, as no other logical arguments are being
found to support the enactment of such sections.

But, these were the bare provisions- if we now look at the exercise of the arbitrary and
discretionary power of the CBFC in the most unreasonable manner, we can easily find out three
glaring instances-

1. Bandit Queen (1994)- This film was being contested for banned on grounds of nudity,
sexual exposure and violence. The person, on whom the movie was made herself
contested on its‘ accuracy and truth, and urged to get it banned. But, though the CBFC
allowed to release it, but with a lot of cuts and restricted screening. Later, this film went
onto become a cult classic, with numerous critical acclaims , like the Filmfare Award for
Best Movie and Best Direction, and also got screened in numerous international film
festivals.
2. Garam Hawa (1973)- This was a movie based on the times of partition, with the story
centering and revolving around a Muslim business man family. This again caught the
glare of the CBFC, this time on grounds of religion and communalism, and was censored
at several parts, and was given a restricted release, at only a few places. Still, it won great
critical acclaim, and went onto become one of the cult classics of Indian Cinema in the
subject of partition.
3. Kissa Kursi Ka (1977)- This film was based on the Indian politics and Parliament and
probably saw the most glaring act of the Central Government, where the movie was
banned in and out, with alleged allegations of forecasting a particular Indian political
family in a bad light. Later, when the Government changed, there was an attempt to
revive the film and release it, but no negative was found. This movie stands as a classic
 example of how the suitability of a film for the masses depends solely on the Central
Government and nothing else.

Forty-six years ago, the film-maker K.A. Abbas challenged the constitutionality of the pre-
censorship regime established by the Cinematograph Act, as well as the Guidelines framed under
it. Abbas‘s argument was that pre-censorship was too draconian to be a ―reasonable restriction‖
upon free speech under Article 19(2). This was especially so because other media of
communication, such as print, were not subjected to pre-censorship. In any event, he argued, at
the very least, the Guidelines were entirely vague and arbitrary

However, it was Abbas‘s misfortune that his case came to be heard before a bench led by a judge
who had not only shown himself to be hostile to the freedom of speech and expression, but also
fancied himself as an art and culture critic — a lethal combination. Five years before, Chief
Justice M. Hidayatullah had upheld a ban on D.H. Lawrence‘s Lady Chatterley‘s Lover by
dismissing its artistic qualities as worthless, and had adopted a 19th century legal test for
obscenity focused on preventing moral ―depravity‖ and ―corruption‖.

Now, in writing the court‘s opinion on film censorship, he not only upheld the Act and the
Guidelines, but also embarked upon a psychological analysis of how the medium of cinema, with
its ―versatility, realism (often surrealism), and its coordination of the visual and aural senses‖
was able to ―stir‖ people much more deeply than written words could, and, therefore, had to be
subjected to a more stringent regulatory regime. Strangely, Chief Justice Hidayatullah‘s
reasoning in K.A. Abbas was strongly reminiscent of the ―argument from colonial difference‖,
used by the British to deny Indians civic freedoms and the right to self-governance for the
longest time. The British had regularly invoked the emotional, mental and political immaturity of
Indians to justify both their rule, and the necessity of imposing a repressive censorship regime
upon the press and the arts. Independence had come, and a new Constitution, but the same
Indians who were now considered politically mature enough to govern themselves and choose
their own leaders, could still not be trusted by the Supreme Court to watch films without the
prior approval of the government.

K.A. Abbas was an unfortunate judgment because it not only upheld the Cinematograph Act and
its vague guidelines but also created a judicial discourse around films and the freedom of speech
that is defined by its moralising, patronising, and paternalistic character. A little over a decade-
and-a-half later, in S. Rangarajan vs P. Jagjivan Ram6, the Supreme Court observed that pre-
censorship of films was necessary because cinema audiences were not as ―discerning‖ as
newspaper readers. Nearly a decade later again, in the Bandit Queen case, the Supreme Court
permitted some scenes of violence and frontal nudity on the ground that they served a larger
social purpose of creating, in the minds of the viewers, a revulsion towards such actions — and
that the scenes were no longer and no more detailed than was strictly necessary to serve this
purpose.

This K.A. Abbas incident and the subsequent issues bring it out very clearly about the never
ending battle between the CBFC and the film fraternity, whereas sometimes the judiciary
supported the film fraternity and sometimes the CBFC.

But, in the recent few years, the former chairman had in particular taken a very stringent stand on
censorship- with some of his acts, like banning Udta Punjab on grounds of being tarnishing the
image of the particular State, and later agreeing for 100 cuts, which was later resolved by the
Bombay High Court and agreed upon as a single cut. The movie later on became a huge
commercial success.

Then, there came the issue of Padmavat, which was even banned on grounds of hurting the
feelings of a particular community, and for depicting their legendary queen in an ‗indecent‘
manner. Again, the Supreme Court had to intervene an allow the screening of the film.

Several such rigorous censorship incidents took place, and on varied issues, ranging from
sexuality to religion to violence and to obscene language.

CHANGE IN THE SCENARIO

On 1st January 2016 in sync with the overarching vision of the Hon‘ble Prime Minister of India,
Shri Narendra Modi and Hon‘ble Union Minister of Information & Broadcasting, Shri Arun
Jaitley, to lay down a holistic framework for certification of films, a Committee was set up under
the Chairmanship of Shri Shyam Benegal to lay down norms for film certification that take note
of best practices in various parts of the world and give sufficient and adequate space for artistic

6
1989 SCC (2) 574
and creative expression, lay down procedures and guidelines for the benefit of the CBFC Board
to follow and examine staffing patterns with a view to recommending a framework that would
provide efficient and transparent user friendly services.

Based on the recommendations of the Shyam Benegal Committee, Mr. Shashi Tharoor proposed
the Cinematograph (Amendment) Bill, 2018, based on the following reasons-

1. Arbitrary decisions of the CBFC

2. Government Tyranny as evident in past cases
3. Social consciousness not taken care of inn most cases
4. Judicial pronouncements, granting artistic freedom and autonomy as in Udta Punjab and
Bandit Queen
5. Opinion of film experts and jurists
6. Respecting the changing social trend
7. No express provision of children and express bifurcation in the old Act
8. The board used to make recommendations, and now it changes under the old Act.

An overview of the new proposed Act may be presented,

First of all, it certifies the movies on the following basis-

1. U- a movie accessible to all

2. U/A- 12+ - to be viewed by children below 12 only with consent of parents.
3. U/A- 15+- to be viewed by children below 15 only with the consent of their parents.
4. A- to be viewed only by adults
5. A-C- only for adults but with extra violence, sexuality or nudity
6. S- to be viewed only by a special class of persons, based on caste, region, religion or
profession.

Also, this Act rules out the possibilities of censorship, as the Board cannot give any
recommendations or restrictions, but only can refuse to certify the movie under a certain
categories, but is obligated to grant another category as per its‘ convenience. So, if the filmmaker
is contented with any category that he gets, there‘s no chance of having a ‗cut‘ in his/her movie,
forget about being shelved off. Furthermore, the director should clarify the classification sought
and the target audience.

Bifurcations or certifications, has to be decided on the basis of sole four criterions-

1. Context
2. Tone and impact
3. Target Audience
4. Theme

On each category, there has to be eight heads to judge the grant or refusal of a particular section-

1. Discrimination
2. Psychotropic substances
3. Imitable behavior
4. Language
5. Nudity
6. Fear, threat and horror
7. Violence
8. Sex

After getting a technical overview of the bill, if we now tend to focus at the various advantages
and disadvantages that it would bring out, if it gets ratified by the Parliament.

Advantages-

1. Shift of liability on law enforcement agency, as a film cannot be shelved as potential

threat to law and order- it‘s the duty of the law enforcement bodies to maintain it.
2. Artistic Freedom has been given due importance
3. Social change has been provided a due importance
4. The society and country would be given shown in the film would be given due
importance, but contemporary society may be ignored upon.
5. Due importance has been on to the presence and use of horror, as an element of
certification criteria.
 6. The word ―reasonable‖ has been used too many a times, giving it a form of a judicial
pronouncement.
7. The word that the classification and the target audience should be disclosed so that a
counterbalanced sheet of expectations may be discussed.
8. The changes and cuts are to be made at the discretion of the director himself/herself.
9. Fifteen days are being given to the director to present and argue his case.

Disadvantages-

1. By reasonable means- is a very vague and wide or narrow terms.

2. No reasonable safeguard has been placed against it.
3. Social change would be referred to as a subjective meaning.
4. U- family friendly- What is the definition of family friendly- what if all the members are
adults- above 18?
5. U/A- 15 + - ‗adolescents‘ word has been used but does not deal exclusively with
adolescent.
6. Target audience- how to determine this ?- isn‘t narrowing down the concept of film
viewership?
7. No remedy lies against the decision of the board- Section 5 (ii)
8. The word ―may‖ has been used too often, giving rise to no certainity and ambiguity.
9. Fifteen days may not be sufficient time to present his argue case.
10. The exceptions to the freedom of speech and expression must be interpreted and read in a
strict and narrow manner.

The chairman acts as a guiding and ceremonial post with non – participation in day to day affairs
of the board. The limited quantum forcing to confine the number of members to only nine and
one chairman, with limited functions on basis of existing CBFC rules, annual review of CBFC
work, by submitting annual report to Government, and by reviewing of public reaction to film,
and periodic recommendation for revision of guidelines.

CONCLUSION

At the end of it all, after a history of 100 years of censorship of films in India, there has been a
noble attempt to free the filmmakers from the clutches of censorship. Although the bill has a lot
of questions to be answered-like whether censorship is to apply to motion posters but also to
films? Why is there still certification in a modern democracy and why the State gets the
opportunity to decide on behalf of the citizen s following a inductive approach? But, still, it is a
significant step that has to be appreciated, and even if it‘s not flawless, but yet, it is a great step,
that has to be commended, as it envisions a better and more liberal society, both in terms of its‘
creation and its‘ regulators.