Delhi HC Upholds CBFC Ban on Film ‘Masoom Kaatil’ for Promoting Vigilantism, Communal Disharmony [Read Judgment]

New Delhi: The Delhi High Court has refused to grant certification to a Hindi film titled Masoom Kaatil, upholding the Central Board of Film Certification’s (CBFC) decision to deny exhibition rights due to content promoting vigilantism and communal disharmony.

Justice Manmeet Pritam Singh Arora dismissed the appeal filed by filmmaker Shyam Bharteey, emphasizing that in a diverse, secular society, certification cannot be granted to films that ridicule religions, incite hatred, or threaten social harmony.

The court was hearing RFA-IPD 1/2023, originally filed as a writ petition under Article 226 of the Constitution challenging the CBFC’s refusal to certify the film. The matter was renumbered as an appeal following the abolition of the Film Certification Appellate Tribunal under the Tribunal Reforms Act, 2021.

Bharteey, proprietor of M/s Sanvika Production (New Delhi), had applied for certification on August 9, 2022, paying the requisite fee of ₹23,800. The film was first examined by a five-member Examining Committee in Delhi, which found it unfit for public exhibition and referred it to the Revising Committee in Mumbai.

On September 19, 2022, the eight-member Revising Committee unanimously refused certification, noting: “The film justifies vigilantism, is communal in its portrayal, full of gruesome violence, killings, human cannibalism, expletives, extreme violence on animals, communal and caste remarks, and denigrates religions in a manner likely to incite further violence.”

The court also highlighted the storyline, which follows Anirudh, a vegetarian boy who develops methods to eliminate butchers using chemical knowledge, later joined by his classmate Vedika in a mission to eradicate meat sellers across the country. The narrative portrays minors taking the law into their own hands without accountability.

Justice Arora warned of the dangerous implications: “If a film makes it seem that taking the law into your own hands is something to be admired and celebrated, it can damage people’s trust in the legal system and suggest that using violence instead of following the law is acceptable.”

The court expressed particular concern over the protagonists being school-going teenagers engaged in gore, violence, and anti-social acts—contrary to Rule 2(iii)(a) of the 1991 Guidelines, which prohibits films from corrupting the morality of children and vulnerable audiences.

Referring to Supreme Court precedents in S. Rangarajan v. P. Jagjivan Ram and Raj Kapoor v. Laxman, Justice Arora noted that cinema has the “unique capacity to disturb and arouse feelings” and an “equal potential to cultivate violent or good behaviour,” making censorship by prior restraint “not only desirable but also necessary.”

The court held that the film violated several provisions of the 1991 Guidelines, including prohibitions against glorifying anti-social activities, cruelty to animals, promoting communal attitudes, and offending human sensibilities through depravity.

Rejecting the appellant’s plea for an ‘A’ certificate with cuts, the court observed that both committees had deemed the film fundamentally unsuitable for public exhibition. It also noted that even the official trailer available on YouTube contained disturbing gore.

Justice Arora reiterated that freedom of artistic expression cannot override the statutory framework of the Cinematograph Act, 1952, and that Article 19(1)(a) subjects free speech to reasonable restrictions on grounds of decency, morality, public order, and incitement to offense.

Accordingly, the appeal was dismissed on September 10, 2025, with all pending applications disposed of.

Case Title: Shyam Bharteey vs. Central Board of Film Certification Regional Officer Delhi & Anr.

[Read Judgment]

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