MEDIA AND

CENSORSHIP WITH
REFERENCE TO
CINEMATOGRAPH
ACT 1952
Submitted to: Ms Kritika
Sheoran
Submitted by: Aparna
Goswami
RollNo:84/19
Section: B
Semester: 7th

aparnagoswami19@gmail.com
CONTENTS
1. Introduction
2. Organisational Setup of CBFC
3. Examination of films
4. Advisory Panels
5. Types of Certifications
6. Objectives of Certifications
7. Appeals
8. Common Reasons for Censorship
9. Debate on Certification
10. Constitutionality
11. Criticism of CBFC
12. Need for reform
• Mudgal Committee
• Benegal Committee
13. Proposed Amendments
14. Issues with amendments
15. Judicial Pronouncements
16. Conclusion

1
Introduction
We have often heard the word censorship regarding media especially films. From popular
movies like Udta Punjab to Haider to Lipstick Under My Burkha have faced censorship issues.
All the rules and regulations regarding the censorships are answered in the Cinematography
Act, 1952. As the world is changing the films are becoming more and more innovative to suit
the style of people. The world is appreciating the new type of content which is being shown in
the films. The Indian media and entertainment industry has recently undergone a tremendous
change in terms of both the volume and demand for diverse content as well as the mediums
used by viewers to access it.
Due to the rise of digitalization in India, Over-the-top ("OTT") platforms that provide
affordable entertainment to people of various ages have made people divert their attention from
television to the all-in-one package in their cell phones. Even programs on OTT platforms face
censorship issues.
The Cinematograph Act of 1952 enforces certain guidelines that pacify filmmakers' public
expression of ideas, opinions, and creativeness through films. Cinema has given birth to new
opportunities and contentious issues in the socio-economic and cultural spheres. With the
advancement of technology, it is easy to abuse the wonders of technology and portray themes
that are harmful to social conformities.
In this article we are going to learn more about censorship and how it is affecting various
filmmakers in India, the current regulatory framework for film certification, television program
compliance, and regulatory trends for OTT media platforms.

THE ACT
Organizational setup of CBFC
It is a statutory body under the Ministry of Information and Broadcasting, regulating the public
exhibition of films under the provisions of the Cinematograph Act 1952.
The Board consists of non-official members and a chairman (all of whom are appointed by
Central Government) and functions with headquarters at Mumbai.
Films can be publicly exhibited in India (on cinema halls, T.V. channels) only after they have
been certified by the Central Board of Film Certification. The CBFC is a bi-level association.
It is headquartered at Mumbai and has 9 Regional Offices. These Regional Offices assist in the
examination of films.it is interesting to note that the members of the Advisory Panel are from
different walks of life who are nominated by the Central Government.

Board of CBFC
The actual statutory power to certify films lies with the Board of CBFC. The main CBFC Board
consists of a chairman and other members 12 to 25 in the number who are appointed by the
Central Government. It is interesting to note that there are no prescribed minimum
qualifications required to be a member of the CBFC as under the Cinematograph Act. Tenure
of members is also very flexible and no maximum or minimum tenure is set. The tenure is in

2
fact subjected to the pleasure of the Central Government. The Central Government can
terminate tenure whenever possible on reasonable grounds. The chairman, however, holds
office for a period of 3 years only. On exception, the chairman continues until his successor is
appointed.

Regional Offices of CBFC

The nine Regional Offices have a particular regional officer who supervises it. They are
situated at Kolkata, Bangalore, Chennai, Guwahati, Cuttack, Mumbai, Hyderabad, New Delhi
and Thiruvananthapuram.

Examination of Films (Section 4)

Under Section 4 of The Cinematography Act, 1952 if a person desires to display any film, they
shall do it in the prescribed manner stated under this act.
The person has to make an application to the board for a certificate and the board after
examining or having the film examined in the prescribed manner.
The board has the right to:
i) Sanction the film for unrestricted public exhibition:
Concerning any material in the film, if the Board believes that it is necessary to caution that
the question of whether any child under the age of twelve years should be considered by the
parents or guardians of such child, the Board may sanction the film for unrestricted public
exhibition with an endorsement to that effect.
(ii) Sanction the film for public exhibition restricted to adults; or
[ii(a)] Sanction the film to be shown in public only to members of any profession or class of
people, taking into account the film's nature, content, and theme; or
(iii) direct the applicant to make such cuts or changes to the film as it deems necessary before
sanctioning the film for public exhibition under any of the preceding clauses or
(iv) refuse to sanction the film for public exhibition.

Advisory panels (Section 5)

(1) To enable the Board to efficiently discharge its functions under this Act, the Central
Government may establish advisory panels at such regional centres as it deems appropriate,
each of which shall consist of the such number of persons, being persons qualified in the
Central Government's opinion to judge the effect of films on the public, as the Central
Government deems appropriate to appoint.
(2) At each regional centre, the Central Government may appoint as many regional officers as
it sees fit, and rules enacted in this regard may provide for the association of regional officers
in film examination.

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(3) The Board may consult in such manner as may be prescribed, any advisory panel in respect
of any film for which an application for a certificate has been made.
(4) It shall be the duty of every such advisory panel whether acting as a body or in committees
as may be provided in the rules made on this behalf to examine the film and to make such
recommendations to the Board as it thinks fit.
(5) The members of the advisory panel shall not be entitled to any salary but shall receive fees
or allowances as may be prescribed.

Types of Certifications (Section 5A)

There are mainly four kinds of certifications given by the Central Board of Film Certification:
1. Universal (U)
This type of certification is known as Unrestricted Public Exhibition, and it has no age
restrictions on who can watch it. They could be about family, education, or social issues. This
category contains fantasy violence with only minor foul language. When a film is certified U
by the Board, it must ensure that it is appropriate for a family to watch together, including
children.
Example: Frozen, Tangled, etc.

2. Parental Guidance (U/A)

This type of certification shows that the film is suitable for all ages. But to be accompanied by
their parents is in the interests of children younger than 12. The reason could be that without
the supervision of their parents the concept of the movie may not be appropriate for the child.
Example: Force, Ghajini, Kabali, etc.

3. Adults Only (A)

This type of film is intended for adults only, as the certification indicates. Adults are defined
as people over the age of 18 in the context of this certification. The theme may contain
negatively affecting, intense, drug abuse, and other related scenes that are not suitable for
viewing by children who may be significantly affected by the same. Films that meet the above
criteria but are not suitable for showing to children or those under the age of 18 will be certified
A.
Example: Grand Masti, Delhi Belly, etc.

4. Restricted to Special Class of Persons (S)

This is the final type of certification under the board, and it explains that films rated S are only
intended for a specific group of people. Doctors, for example. If the Board determines that the

4
film's content, nature, and theme should be restricted to members of a specific group or
profession, the above certification shall be granted to the film.

Objectives of film certification [Section 5B (2)]

The main objectives of the Board for the above are as follows:
1. To ensure that the film medium is held accountable. Furthermore, to protect the sensitivity
of standards and societal values.
2. To ensure that creative freedom and expression are not inadvertently restricted.
3. To ensure to make adjustments according to the current changes in society.
4. To ensure that the film's concept provides healthy and clean entertainment.
5. To ensure that the film is of an appropriate cinematographic standard and artistic value.
6. To ensure that the film is judged in its entirety and not from a one-tracked biased perspective.

Appeals (Section 5C)

(1) Any person applying for a certificate in respect of a film who is aggrieved by
any order of the Board—
(a) refusing to grant a certificate; or
(b) granting only an “A” certificate; or
(c) granting only an “S” certificate; or
(d) granting only a “UA” certificate; or
(e) directing the applicant to carry out any excisions or modifications,
may, within thirty days from the date of such order, prefer an appeal to the Tribunal:
Provided that the Tribunal may, if it is satisfied that the appellant was prevented by sufficient
cause from filing the appeal within the aforesaid period of thirty days, allow such appeal to be
admitted within a
a further period of thirty days.
(2) Every appeal under this section shall be made by a petition in writing and shall be
accompanied by a brief statement of the reasons for the order appealed against where such
statement has been furnished to the appellant and by such fees, not exceeding rupees one
thousand, as may be prescribed.

Common Reasons for Censorship or Banning of a Film

In light of the history of why a film has been banned, or parts of it are censored, the main
categories for why the same is done are as follows:

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 1. Sexuality: A rigid social structure has been followed in Indian society. Hence, a
medium which portrays sexuality regardless of the audio, written or visual form, which
has not been fathomed by the society and is concerned a social stigma is banned on the
grounds that it might have the effect of undignified morals of Indians.
2. Politics: The isolation of political forces is not far when one talks about censorship.
The description of an allegorical political scene, directly or indirectly, is banned by the
authorized party to it. Overt political overtones are not appreciated by the government
and hence is a common reason why certain films are either entirely banned, or such
scenes are censored or removed.
3. Communal Conflict: Under a heterogeneous nation like India, if a film incites or spurs
any type of communal conflict, the same is censored. The aim is to avoid the
consequences such a film would have on the audience it intentionally or unintentionally
targets. If the state believes that a movie would open a window for riots by a community
for the way they have been portrayed in the film, the same is banned by the Board or
censored.
4. Incorrect Portrayal: Sometimes, a situation arises where a well-known personality
objects his own depiction in a medium which would be exhibited, and consequently
goes for censoring the same. For more clarity, in a situation where the medium is of
biographical nature, and the person on whom it is based does not approve the
authenticity of the same, there have been times when the person has sued for the
medium not to be released, or be edited and released upon approval of such person.
5. Religion: Religion does not appreciate any type of defiance or disobedience towards
the values it proliferates. Hence, any medium which directly or indirectly distorts any
aspect of the religion including its preaching, values, idols, to name a few, is highly
criticized and therefore, censored.
6. Extreme Violence: Indubitably, the portrayal of extreme gore and violence may
meddle and disturb the human mind. Viewing such scenes may have a negative
psychological effect on the mind. If the Board of a similar opinion that such a scene
through any medium may have an underlying negative impact on the viewer, contrary
to the entertainment or knowledge such scene tries to bestow, the same may be banned,
edited or censored by the Board in public interest.

Debate on Certification
Section 5B of the Act lays down the principles governing the certification of movies and
provides the grounds to deny certification. These are the sovereignty and integrity of India, the
security of the state, friendly relations with foreign states, public order, decency or morality,
or involves defamation, or contempt of court or is likely to incite the commission of any
offence.
In furtherance of powers under the Act, the central government issued guidelines on 6
December 1991 for CBFC certification. The draft bill proposes a proviso to sub-section 1 of

6
section 6 that if section 5B(1) of the Act is violated, the central government may direct the “re-
examination” of the film.
However, this amendment seeks to alter the Supreme Court ruling in Union of India vs KM
Shankarappa, 2001, which held that the government cannot interfere in a film that is once
certified in compliance with the Act.
Interference would amount to an additional level of censorship, over and above the certification
process, which would violate the guaranteed right to free expression.

Constitutionality
The Cinematograph Act sets forth the principal tenet which should guide the censorship
authorities in certifying films for public exhibition. Because Section 5B (1) of the Act is merely
a general restatement of Article 19(2) of the Indian Constitution, the Act further provides that
the Central Government may issue directions delineating more fully the principles of film
censorship.
Unlike the First Amendment to the US Constitution, which unequivocally declares: “Congress
shall make no law . . . abridging the freedom of speech, or of the press”; constitutional
guarantee of free speech in India is somewhat restricted. Article 19(1)(a) of the Constitution of
India promises right to free speech and expression to all the citizens. However, „reasonable
restriction‟ can be imposed on the enjoyment of this freedom by the
State under clause 2 of Article 19 on certain grounds, i.e., the interests of the sovereignty and
integrity of India, the security of the State, friendly relations with foreign States, public order,
decency or morality, or in relation to contempt of court, defamation or incitement to an offense.
Additionally, freedoms under Article 19 of the Constitution can be suspended during the
Emergency by virtue of Article 359.
The Constitution does not specifically speak about any medium of communication. The
jurisprudence that has developed through case laws in this respect has encompassed the press,
motion pictures, advertisements etc. within its fold. So far censorship of films in India is
concerned, the power of legislation is vested with the Parliament under Entry 60 of the Union
List (or List I)20of the Schedule VII of the Constitution.
The States are also empowered to make laws on cinemas under Entry 3321 of the State List (or
List II)22but subject to the provision of the central legislation. The prime legislation in this
respect is the Cinematograph Act, 1952 and the Cinematograph (Certification) Rules, 1983.

Criticism of CBFC
The CBFC has been criticised for a number of reasons. It has been alleged of being
unreasonable while exercising the power of censorship. Sometimes the CBFC has
unreasonably ordered the deletion of major or effective parts of the film. The main problem
with such orders is that it dampens creativity of the film. And also shows disregard for the
efforts and dedication put in by the filmmaker and his supporting team and of course the cast.

7
The fundamental right to freedom of expression under Article 19(1)(a) of the Indian
Constitution is violated.
A lackadaisical outlook of the board shows their unreasonably and meaningless cuts in a film
may lead to not only wastage of effort but also financial resources. Many critics have viewed
this as a mockery of the entire film fraternity.

Need for reform in the CBFC and the Statute

In recent times it has been debated that the CA, 1952 is a pretty outdated statute. The colonial-
era Statute needs to be updated as the societal mindset has changed and the standard of visual
entertainment has also changed. Famous director Rakeysh Omprakash Mehra has stated that
society has adapted itself to a different world and therefore, it is high time that things go to the
next level. With the advancement in technology and the amount of connectivity and
information available nowadays benefits the film industry in more ways than one. However,
the age-old statute restricts a few of the creative possibilities due to its backwardness. An
immediate change is the need of the hour. The time when the act was passed cannot be applied
to the present.
The Mudgal Committee has recommended a few important changes. One of the most
important recommendations was the need for change in name of the ‘advisory panel’ to
‘screening panel’. The committee also recommended that the panel must consist of 9 members
in such a manner in order to ensure language diversity via representation. At least 2 lady
members must be included. The Mudgal committee also mentioned that the present method of
appointment is more political than practical. It is also observed that the CBFC often contains
members who have little knowledge of the intricacies of Indian cinema and the real societal
standards.
Another suggestion was to widen the scope of jurisdiction of the Film Certificate Appellate
Tribunal. The suggestion is that tribunals can hear cases regarding objection in the film rather
than courts. This would save time and resources a bit more than the usual tedious court
procedure.
Shyam Benegal Committee: The Shyam Benegal committee was established on January 1,
2016, to develop important rules and measures for film certification by ensuring the film has
innovation and creativity.
• The recommendations include planning the size of the board and its respective
functions.
• It was also mentioned that women should have 50% representation on each Panel.
• Online submission of applications as well as simplification of forms and accompanying
documentation should be done.
• Recertification of a film for purposes of the telecast on television or for any other
purpose should be permitted.
• In order to preserve Indian Cinema, the committee recommends that every applicant be
asked to deposit the Director’s Cut in the NFAI for the preservation of Indian Cinema,
instead of the certified version.

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Proposed Amendments and Consequences
Provision of Draft Cinematograph (Amendment) Bill, 2021:
Granting Revisionary Powers: The government on account of violation of Section 5B (1) of
the Cinematograph Act, 1952 can order for “re-examination” by the certification board of an
already certified film, following receipt of complaints.
Section 5B (1) deals with the principles for guidance in certifying films. It is derived from
Article 19(2) of the Constitution and is non-negotiable.
Under Section 6 of the existing Cinematograph Act, 1952, the Centre is already empowered to
call for the record of proceedings in relation to certification of a film and pass any order thereon.
The Central Government, if the situation warranted, has the power to reverse the decision of
the Board.
Sub-division of Existing UA Category: The provisions relating to certification of films under
“unrestricted public exhibition (U/A)” category are proposed to be amended so as to sub-divide
the existing UA category into age-based categories like U/A 7+, U/A 13+ and U/A 16+.
Film Piracy: In most cases, illegal duplication in cinema halls is the originating point of piracy.
At present, there are no enabling provisions to check film piracy in the Cinematograph Act,
1952. The draft Bill proposes to insert Section 6AA which prohibits unauthorised recording.
Punishment for Piracy: Section 6AA of the draft legislation makes piracy a punishable
offence. The punishment of imprisonment for a term up to three years and with a fine which
shall not be less than Rs 3 lakh but which may extend to 5% of the audited gross production
cost or with both.
The recommendations of the Justice Mukul Mudgal Committee of 2013 and the Shyam
Benegal Committee of 2016 had also been considered while drafting the legislation.
One of the amendments to the Cinematograph Act empowers the government to order the re-
examination of a film already cleared by the Central Board of Film Certification. Critics have
said the proposed change was the government’s attempt to create a “super censor”.

Members of the Congress MP Shashi Tharoor-led parliamentary committee asked the Ministry
of Information and Broadcasting to explain why such a provision was going to be introduced
in the Cinematograph Act, an unidentified official told The Hindu.
The parliamentary panel’s members also cited a 2000 Supreme Court order, which noted that
the Centre could not have revisional powers over films already cleared by the Central Board of
Film Certification, the newspaper reported.
The Information and Broadcasting ministry has, however, told the committee that the central
government would only invoke the “super censorship” clause in case a film had an impact on
national security and integrity.

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Issues with the Cinematograph (Amendment) Bill 2021
The Cinematograph (Amendment) Bill 2021 has caused a great turmoil in the Indian film
industry as it threatens the autonomy of the CBFC & film makers. They are of the opinion that
by giving revisionary powers to the central government, they will be left powerless and will be
exposed to vandalism, harassment as well as mob-censorship. The proposed amendments will
give the Central government ultimate dominion over the films curtailing the freedom of speech
and expression, which has been ensured to each and every citizen of the country.
Providing Central government with reversionary powers regarding film certification is in
contravention to the judgement given in K. M. Shankarappa v. Union of India, where the
Hon’ble Supreme Court held that once the films are certified by CBFC, in such case the Union
government cannot exercise its revisional powers.

If the Central government will be provided with revisional powers, then the Producers can
never be certain regarding certification of their film, even after being granted with certification,
there will be a possibility that their film certification will be re assessed and undergo a
subsequent certification. India is a country with numerous cultures and people belonging to
such cultures will have a different perspective and if films will be judged through a cultural
perspective, then it will lead to a moralistic & subjective assessment of films, immaterial of
whether the film is certified or not.
The Cinematograph (Amendment) Bill, 2021 neither expressly includes the OTT platform nor
excludes it. However, similar regulation/restriction has been imposed on the OTT platforms
through the Information Technology Rules 2021. Due to such stringent provisions, OTT
platforms will also need to thoroughly inspect the films for red flags because if they do not
comply with the provisions there will be a risk of getting banned and hence the OTT platforms
will avoid such films altogether. This will negatively impact the filmmakers

Judicial Pronouncements
1. Raj Kapoor vs. Laxman1
Subject Matter: Certification of films
Issue: Whether certificate issued would amount to a justification for the public exhibition?
The complainant claimed that the film Satyam Shivam Sundaram was misleadingly foul and
deceived the unwary into degeneracy due to its intriguing title and that vulgarity, indecent
exposure, and vice were writ large on the film, constituting an offense. Following the

1
AIR 1979 SC

10
examination of some witnesses, the Magistrate took cognizance of the offense and issued a
notice to the appellant-producer of the film.
The appellant then petitioned the High Court, claiming that the criminal proceeding was an
abuse of the judicial process and that no prosecution could be legally sustained because the
film had been duly certified for public viewing by the Central Board of Film Censors. However,
the petition was denied by the High Court, and thus an appeal was filed.
The Supreme Court ruled that a certificate issued under Section 5A of the Cinematograph Act
constitutes a legal justification for a film's public exhibition and that the initiation of criminal
processes for obscenity is not sustainable if the film has been approved by the censor board.
The court did, however, state that the bar is not absolute, and that the filmmaker must
participate in the legal proceedings to claim the safeguard.

2. In the landmark case of K.A Abbas v. Union of India2, 1970, the certification process was
challenged on the ground that censorship violated the freedom of speech and expression under
Article 19(1)(a). The Supreme Court held—and this remains the law to date—that censorship
and categorization of films based on age groups of viewers are justified in the interest of public
morality and decency.
The court justified its reasoning based on the notion that cinema impacts the viewers more
deeply when compared with other forms of art such as a painting or a book.
The Court explained the broad legal governing principles on the censorship issue related case
Srishti School of Art, Design and Technology v. Chairman, CBFC3. the following points
were summarised in 2011 by the Delhi HC:
• Reasonable standards must be adopted while judging.
• The onus of proof of obscenity must be provided by the petitioner (Government).
• The film must be judged in its entirety in order to determine whether a particular scene
in it offends Cinematograph guidelines or not.
• The Petitioners must also prove the proximate and direct nexus of the film to
endangering public order
• The courts shouldn’t ordinarily disregard CBFC’s decisions regarding film certification
unless it is proven to be unreasonable.

3. S. Ranga Raan v. P. Jagjivan Ram4

The issue in S. Ranga Raan v. P. Jagjivan Ram was whether the Tamil film "Ore Oru
Gramathile" should be granted the "U" certificate. The film appears to condemn the
exploitation of people based on their caste.

2
AIR 1971 SC 481
3
2011 IIIAD (Delhi) 289
4
1989) 2 SCC 574

11
The Supreme Court ruled that as long as there is no proclamation in the film that threatens to
take over the government through unlawful means and no indication of impairment in the
country's integration, the U certificate can be granted.
the Supreme Court observed, “If the film is unobjectionable and cannot constitutionally be
restricted under Article 19(2), freedom of expression cannot be suppressed on account of threat
of demonstration and processions or threats of violence…It is the duty of the State to protect
the freedom of expression since it is a liberty guaranteed against the State.”

4. In Gita Ram v. State of HP5

the appellants were caught while showing the blue film named “size matter” to young men in
their premises. The wrongdoers were convicted and sentenced accordingly for an offence
punishable under Section 292 r/w Section 34 of the Indian Penal Code. They were also
subjected to Section 7 of the Cinematograph Act.
5. Life Insurance Corporation vs Prof. Manu Bhai D Shah6, related to a documentary about
the Bhopal Gas Tragedy that national television channels refused to air. The Supreme Court
held that merely because a documentary is critical of the government is no reason to deny its
publication.
Recent Cases
In Indibility Creative Private Limited vs Government of West Bengal, 2019, the Supreme
Court held that once the CBFC has cleared a movie for release, the government cannot halt its
release on the ground that there may be a law-and-order situation.
Justice DY Chandrachud said, ‘Unless we were to read a positive obligation on the state to
create and maintain conditions in which the freedoms guaranteed by the Constitution can be
exercised, there is a real danger that art and literature would become victims of intolerance.’

The Bombay High Court noted in Phantom Films Pvt Ltd vs The Central Board for Film
Certification, 2016, that the “…ultimate censorious power over the censors belongs to the
people and by indifference, laxity or abetment, pictures which pollute public morals are
liberally certificated, the legislation, meant by Parliament to protect people’s good morals,
maybe sabotaged by statutory enemies within….”

Conclusion
The Cinematograph (Amendment) Bill, 2021, takes a step towards preventing and punishing
film piracy that has haunted the film industry for several years. However, vesting revisional
powers with the Central government will lead to severe inconvenience and harassment of film
makers. It takes away the power of CBFC and the Central government can direct the Board to

5
AIR 2013 641
6
1992

12
re-examine a film that has already been certified until it is satisfied. Hence, the Central
government should not be vested with revisionary powers.
To conclude this, I would like to say that Article 19(1) (a) of the Indian Constitution guarantees
freedom of speech and expression, but it is also limited by Article 19(2), which allows the
government to impose “reasonable restrictions” on this right “in the interests of the sovereignty
and integrity of India, the security of the State, friendly relations with foreign States, public
order, decency or morality, or concerning contempt”. This gives the government a wide net to
censor almost anything that is not in their favour.
Censorship, in many ways, not only silences speech but also produces authorized forms of
truth. This is relevant not only to the cinema but also to the broader issues of all human
creativity. It is argued that its conflicts over free speech are increasing.
There have been a few statements levelled at the CBFC, with corruption and nepotism limiting
the fairness of this industry, and the CBFC itself being accused of being irrational. The
censorship guidelines are reviewed regularly in the best interests of the viewing public,
changing society, and public suitability. The CBFC must be restructured, as well as the
Cinematograph Act of 1952 should be amended.

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REFERENCES
Book
• Madhavi Goradia Diwan, Facets of Media Law (Eastern Book Company, Lucknow,
2nd Edition, 2013)
Journals & Articles:
• Arpan Banerjee, “Political Censorship and Indian Cinematographic Laws: A
Functionalist-Liberal Analysis”, 2 Drexel L. Rev. 557 (2010)
• Someswar Bhowmik, “Politics of Film Censorship: Limits of Tolerance”, 37 ECON.
& POL. WKLY. 3574, 3577 (2002)
• Sreejita Mitra, A Socio-Legal Perspective of the Cinematograph, Act, 1952, ©2019
IJLMH | Volume 2, Issue 2 | ISSN: 2581-5369

Online contents
• Sarkar, S., „RIGHT TO FREE SPEECH IN A CENSORED DEMOCRACY‟,
Available at https://www.law.du.edu/documents/sports-and-entertainment-law-
journal/issues/07/right.pdf Last accessed on 21 November 2022
• Borkar, S., „Modern Day Law for the Modern Indian Cinema ( Indian Cinematograph
Bill, 2018 {Insights , Highlights, Proposals, Drawback, Analysis})‟, Available at
http://www.mondaq.com/india/x/778618/broadcasting+film+television+radio/Modern
+Day+Law+for+the+Modern+Indian+Cinema+Indian+Cinematograph+Bill+2018+In
sights+Highlights+Proposals+Drawback+Analysis Last accessed on 21 November
2022.
Acts
• The Cinematograph Act, 1952 (Act 37 of 1952)
• The Cinematograph Amendment Bill 2021

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