Madras High Court Upholds ‘A’ Certificate for Film ‘Coolie’ | CBFC’s Certification Discretion under Cinematograph Act Affirmed | Artistic Freedom Must Align with Statutory Guidelines
Sanchayita Lahkar
The High Court of Judicature at Madras Single Bench of Justice T.V. Thamilselvi held that the appellant’s challenge to the certification granted by the Central Board of Film Certification could not be sustained and dismissed the appeal on merits. The Court directed that the certification issued by the Board shall stand and declined to interfere with the decision of the Examining and Revising Committees. The Court recorded that the Committees had acted within the framework of the Cinematograph Act, 1952, the Cinematograph (Certification) Rules, 2024, and the Guidelines issued thereunder. The Bench concluded that the appellant’s grounds were without legal foundation and that the statutory framework permitted the producer to seek recertification with modifications if desired. Ultimately, the Court dismissed the Civil Miscellaneous Appeal, confirming that there shall be no order as to costs.
The matter arose from the appellant’s challenge to an order of the Central Board of Film Certification (CBFC) dated 04.08.2025 in CAO32607202500031. The dispute concerned the certification granted to the Tamil film Coolie. The appellant had applied for certification of the film on 28.07.2025 under Rule 22 of the Cinematograph Rules, 1983. Following examination by the Examining Committee on 31.07.2025, the CBFC informed the appellant that the film could only be certified for adults (“A” Certificate) provided certain cuts were made. The reason cited was that the film contained frequent and extensive violence and depicted celebration of killings.
Aggrieved by the Examining Committee’s findings, the appellant requested a review by the Revising Committee under Rule 25 of the Cinematograph (Certification) Rules, 1983. The Revising Committee viewed the film on 01.08.2025 and issued its decision on 04.08.2025, granting an “A” Certificate subject to modifications. The Revising Committee cited frequent and extensive violence, strong threatening moments, sustained portrayal of smoking and drinking, and occasional use of bad language as grounds for its decision.
The appellant, being a leading television network and film production company, contended that the decision was arbitrary and discriminatory. It was argued that the film Coolie, which starred popular actors including Rajinikanth, Nagarjuna, and Aamir Khan, was produced to commemorate fifty years of Rajinikanth’s film career. The appellant stated that the film depicted the life of a coolie and their struggles and that the inclusion of scenes involving smoking, drinking, and violence was essential for authenticity. The appellant argued that the CBFC had earlier granted “U/A” Certificates to films such as KGF, Beast, and Dasara, which allegedly contained more violence and objectionable content. Therefore, issuing an “A” Certificate to Coolie was contended to be discriminatory and violative of Article 19 of the Constitution.
The appellant further submitted that the total runtime of the film was 2 hours, 50 minutes, and 20 seconds, of which only five minutes depicted violence. It was argued that such minimal content could not be categorized as “frequent and extensive violence.” The appellant further pointed out that the film contained no glorification of drinking, no scenes degrading women or children, and no depiction of sexual violence. It was further argued that both Committees differed in their reasoning and that the Revising Committee failed to properly evaluate the film as a whole.
The respondent, represented by the Additional Solicitor General, opposed the appeal. It was submitted that Section 5B(1) of the Cinematograph Act, 1952, prohibits certification if the film violates the sovereignty and integrity of India, public order, decency, morality, or other listed grounds. Section 5B(2) empowers the Central Government to issue directions for certification. Pursuant to this, the Government had issued Guidelines in 1991. It was argued that the Examining Committee, consisting of four Advisory Panel Members and the Regional Officer, unanimously recommended an “A” Certificate with modifications. The Revising Committee, comprising experts from diverse fields and presided over by a Board Member, viewed the film afresh and also concluded that the film was only suitable for adults, again recommending an “A” Certificate with modifications.
The respondent further submitted that during the oral hearing, the appellant was given the option of a “UA 16+” Certificate subject to substantial modifications. However, the appellant declined to make cuts and agreed to accept an “A” Certificate. Accordingly, the appellant submitted the required Form IX on 04.08.2025, and the “A” Certificate was issued under CC No. DIL/3/13/2025-Che. The respondent argued that having accepted the certification, the appellant was not entitled to later challenge the order as an aggrieved party. It was further submitted that each film is assessed independently and comparisons with other films such as KGF cannot be relied upon.
The respondent also contended that under Section 4(3) read with Rule 22(2) of the Cinematograph (Certification) Rules, 2024, the appellant could apply for fresh certification with modifications if it wished to exhibit the film to a wider audience. It was stated that both Committees comprised experts and acted in accordance with the Act and Rules, and therefore, no interference by the Court was warranted.
The Court noted that the appellant had released the film on 14.08.2025 across India, after accepting the “A” Certificate, but still retained a statutory right to challenge the order. The Court examined the detailed findings of both the Examining and Revising Committees. The Examining Committee observed that the film contained frequent and extensive violence with few gory images, characters celebrating killing or inflicting injuries, frequent threatening moments, occasional bad language, and consistent focus on smoking and drinking. The Revising Committee, after viewing the film in entirety, concurred and reiterated similar grounds.
The appellant relied upon Supreme Court precedents including K.A. Abbas v. Union of India (1970) and S. Rangarajan v. P. Jagjivan Ram (1989) to argue that the CBFC must evaluate films from the perspective of a reasonable and strong-minded person, and that the approach must consider the theme and context. The respondent countered that the Committees, consisting of members from diverse walks of life, had applied the guidelines in accordance with law, as supported by observations in the same precedent judgments.
Justice T.V. Thamilselvi recorded the judicial reasoning after examining the rival contentions, statutory provisions, and committee reports. The Court observed: “The film is evaluated in its overall aspects. This action film contains frequent and extensive violence throughout the movie, with very few gory/brutal image. Few characters in the movie characterised as celebrate killing or inflicting pain/injuries along with frequent severely threatening moments with occasional bad language. There is also consistent focus on smoking and drinking. Hence the film is recommended for ‘A’ Certification.”
The Court noted that this was the unanimous finding of the Examining Committee. With respect to the Revising Committee, the Court recorded: “The film is evaluated in its overall aspects. The content and presentation portrays frequent and extensive violence, frequent strong threatening moments, along with sustained portrayal of smoking and drinking with occasional bad language. Hence the film is recommended for ‘A’ Certification.”
The Court recorded that both Committees comprised members from diverse fields and represented a cross-section of the community. Both had viewed the film in its entirety and arrived at similar conclusions. The Court rejected the argument that the Revising Committee had differed in its reasoning from the Examining Committee.
The Court observed that Section 5-B of the Cinematograph Act, 1952 provides principles for guidance in certifying films and prohibits certification if a film is against sovereignty, integrity, public order, decency, or morality, or incites offences. The Court noted that the Guidelines for Certification of Films for Public Exhibition issued in 1991 require that anti-social activities such as violence are not glorified, scenes of violence or horror are not needlessly shown, and glorification of smoking and drinking is not permitted.
The Court referred to the appellant’s argument that the film depicted the real-life struggles of coolies and that the inclusion of drinking and smoking scenes was necessary for authenticity. However, the Court recorded the respondent’s contention that the appellant had been given the option of a “UA 16+” Certificate subject to modifications but had declined. The Court observed that: “The appellant was also heard and informed that if he desired a ‘UA 16+’ Certificate, substantial modifications in visuals would be required. However, the appellant agreed to accept an ‘A’ Certificate without opting for such modifications. The Revising Committee unanimously concluded that the film, viewed in its overall aspects, portrayed frequent and extensive violence, strong threatening moments, sustained portrayal of smoking and drinking, and occasional bad language. Hence, the film was recommended for ‘A’ Certification.”
The Court examined the reliance on Supreme Court precedents by both sides. Referring to K.A. Abbas v. Union of India, the Court noted the principles to be applied by censors in examining objectionable content. Referring to S. Rangarajan v. P. Jagjivan Ram, the Court noted the observation: “That the effect of the words must be judged from the standards of reasonable, strong-minded, firm and courageous men, and not those of weak and vacillating minds, nor of those who scent danger in every hostile point of view.”
However, the Court also referred to paragraph 52 of the same judgment, where the Supreme Court recorded: “In this case, two Revising committees have approved the film. The members thereof come from different walks of life with variegated experiences. They represented the cross-section of the community. They have judged the film in the light of the objectives of the Act and the guidelines provided for the purpose. We do not think that there is anything wrong or contrary to the Constitution in approving the film for public exhibition.”
Based on these principles, the Court found no illegality or arbitrariness in the CBFC’s decision.
After analysing the rival submissions and relevant statutory provisions, Justice T.V. Thamilselvi concluded:
“Considering the submissions of both sides, as well as the reports of the Committees, it is revealed that the members of both Committees unanimously resolved to issue an ‘A’ certificate with certain modifications. The appellant was also informed that if he desired an ‘Unrestricted UA 6+’ rating, substantial modifications in visuals would be required. The option of choosing a ‘UA 16+’ rating was also given to him. However, the appellant did not agree to accept excisions or modifications in view of the theme of the movie. It was further clarified that if the petitioner was inclined to execute the modifications, he could re-present the movie for certification under the ‘UA+’ category even still that liberty is available to the appellant. Therefore, subject movie was viewed in its entirety, keeping in mind the objectives of the Act, and the Committees followed the guidelines for certification of films for public exhibition with paramount consideration of social impact on young generation. Therefore, the contention of the appellant is devoid of merits.”
The Court therefore held: “Accordingly, the Civil Miscellaneous appeal is dismissed as on merits. There shall be no order as to costs.”
Advocates Representing the Parties
For the Appellant: Mr. J. Ravindran, Senior Counsel for M/s. M. Sneha
For the Respondent: Mr. A.R.L. Sundaresan, Additional Solicitor General, assisted by Mr. A. Kumaraguru, Senior Panel Counsel
Case Title: Sun TV Network Ltd. v. Central Board of Film Certification
Case Number: C.M.A. No. 2441 of 2025 and CMP No. 20616 of 2025
Bench: Justice T.V. Thamilselvi
