CENSORSHIP, CINEMA, AND FREEDOM OF EXPRESSION
ABSTRACT
Let’s start with the very basic question, what is censorship? The Collins objectionable dictionary defines censorship as –“The censoring of books, plays, films or reports especially by government officials, because they are considered immoral or secret in some way. “Since time immemorial the restrictions on free expression by censorship were followed from the Greek Republic of the Papal States to several contemporary governments worldwide. According to Plato, censorship is necessary to preserve high levels of national pride that society can attain with high morals and achieve when ideas that threaten those morality and values are constrained. The origin of the word CENSORSHIP which is supposedly an English term dates back to 443 BCE. It came along from the word “Censor” which meant an officer who would conduct census of an area and keep a check upon the citizen’s morals and conduct. Although with time, the meaning and definition of censorship evolved but the core meaning of it still remained the same i.e. the examination or surveillance to exclude or eliminate something considered. The existence of freedom of expression allows an individual to freely talk and think and to obtain information from source by writing, publication and speeches, without interruption or limitation by the sovereign, under certain restrictions. Cinema is a means of communication which encourages or attracts people to demonstrate the audience's interest through its services.
RESEARCH OBJECTIVES
The research objectives that this paper will deal with are given below:
To understand the meaning of censorship.
To know the meaning of cinema and its role.
To understand Article 19 i.e. “Freedom of Expression”
To know the restrictions of article 19 under the film industry.
To relate the terms censorship, cinema and freedom of expression.
To study various case studies related to censorship for example - The recent controversy of Tanishq advertisement.
RESEARCH QUESTIONS
i. What is Censorship according to different people and how it originated?
ii. What is Article 19 and what are its restrictions?
iii. What is Central Board of Film Certification (CBFC)?
iv. Different Judicial pronouncements on Film Certification and Censorship.
RESEARCH METHODOLOGY
The approach used in this study is of a doctrinal nature and is mainly theoretical, logical and descriptive. The research's use of reference material i.e., papers, bills, legislatures, books, law magazines, publications, and interpretation of judicial decisions are mostly secondary. The analysis is qualitative as it attempts the concepts already set out by legislation to be analyzed and, where possible, to propose better alternatives.
LITERATURE REVIEW
Since censorship has become an important dilemma around the world many people wrote various posts, blogs, and reviews. The researcher went through the following studies in order to have greater knowledge about the concerned topic.
1. “Censorship in India vis-à-vis freedom of speech: Comparison of the extent of censorship laws in India and Abroad by Priyanka Ghai and Dr. Arnind P Bhanu” [1]
This journal article talks about why it is important to consider and investigate the methods and values that direct censorship in India in the current controversy over the unconstitutional mode of censorship employed by India's certification board. This is also an effort to understand why censorship is such a necessary instrument to preserve peace and harmony in the world. The diary looks at censorship in both the past and the present, including its origins, when and how it took place in society. To have a more detailed view of censoring, efforts have been made to recognise both censoring in the United States of America, which is a champion of democracy, and censorial efforts in the People’s Republic of China?
2.“Censorship by George Anastaplo” [2]
This article analyses the censorship history and how it came into effect. In addition, he spoke of freedom of speech and of censorship in the US. Consequently, he said that this is to some degree possible in all levels of power but in the modern age, the government and the rule of law acquire a new importance.
3.“ Laws governing censorship of movies in India by Diva Rai”[3]
This article states that all forms of entertainment, such as film, the press, and social media, are guaranteed constitutional legitimacy under Article 19(1) (a), which guarantees all people of the country the right to free speech and expression. This basic right is unaffected by any reasonable restrictions imposed by the government for the reasons listed in Article 19(2) of the Constitution. The censorship falls under the right to freedom of speech and expression, due to lack of clarity over the medium of communication on ideas in the clause of Article 19(1) (a) and because the fundamental rights are not absolute, reasonable restrictions are also impediment to exercising them. India has adopted the practice of the Censor Board censoring movies to remove any offensive material. It is to adapt the film to the intended audience. The audience is determined by the certificate issued to each film, which specifies the maximum number of people who can watch the film. Further the writer stated that there are certain legislations in India dealing with censorship in movies to reach the satisfactory level of public morality or other reasonable restrictions. The competent authority is entrusted with the responsibility to watch the movie and make suitable suggestions to the makers before issuing the acceptance certificate to release the movie. The writer also discussed The Cinematography Act, 1952 and explained its sections in detail.
4. “Censorship by Elizabeth R. Purdy” [4]
Herein the author spoke of the cause and the limits of freedom of speech when she says that when they want to prevent anyone from speaking, posting or portraying words and images, individuals or organizations are censored. In order to undermine freedom of expression, censors limit speech, label, abstract communications, and freedom of association, books, literature, music, films, television broadcasts and Internet websites. Moreover, some groups have tried or banned publishing books since the invention of the printing press.
5.“A critical overview of censorship in Indian Cinema in the light of the role of CBFC by Satyam Rathore”[5]
The author discusses cinema's role as a medium for the expression of ideas and free thought. He also prefers to emphasise the importance and scope of regulation which is being provided under the Cinematograph Act of 1952. The author further elaborates on the role of the Censor Board in the certification of films as established under the rule of law. The author adds to it by citing several case laws decided by Indian courts and also discusses how censorship has been misused in this regard to control the freedom of expression through cinema. Lastly, the author proposes that the delicate balance between freedom of expression and reasonable restriction be maintained and the censor board in order to sustain the rule of law, it should be regulated by law for the betterment of society.
6.“ Film Censorship in India : A reasonable restrictions on freedom of speech and expression by Bruce Michael Boyd” [6]
This article talks about the censorship of films in India and tells that the censorship of films in India is one of the strictest in the world. The authors stated that in India people have paradoxical character as that saints are respected, temple art of Khajuraho and Konarak are advertised but some literacy classic scenes are banned on the ground that they are against the society and obscene. He further stated that there are blatant contradictions in the minds of Indians and also sophist aced rationalization.
7.“Censorship and Freedom of Expression in the Age of Facebook by Benjamin F. Jackson” [7]
The writer tells us about the websites of the social networks and the danger of surveillance in the digital age it was about the limitations imposed on different mail, films, photographs etc. for protecting the communities against darkness and other illegal items. He further states that while, so far social networking sites have acted as very open and unrestricted platforms, they are subject to a variety of external and internal influences as public platforms for discourse to censor concepts and also the censorship by social network websites is particularly troubling. Social media helps people to connect with each other and it also gives power to people to share and make the world more open and connected. And in relation to this most of the social media platforms have openly dedicated themselves to the principles of openness and transparency which results in spreading the information rapidly.
8. “To Censor or Not to Censor: Film and Public Policy by Volga”[8]
The writer states that the freedom of speech and freedom of expression, fundamental rights guaranteed to citizens in Indian Constitution under article 10(1) (a) are central to any discussion on Film and Public Policy as literature, music, virtual arts and films are covered under this article and also it protects the citizens to express their thoughts openly and without any restrictions. The writer also talks about Article 19(2) that this article puts reasonable restrictions to this freedom which includes causing danger to national peace, sovereignty and security affecting moral values, disrespect for the institutions of justice, encouraging crime, affecting relations with another country etc. Further, she stated that the cinema has so much influential power as it can affect a large section of population and after taking this into recognition the state set up a Film Censorship and Certificate Board and the Cinematography Act came into force in 1952 and later on this act also experienced several amendments.
9. “Right to free speech and censorship: A Jurisprudential Analysis by Shameek Sen”[9]
In this research paper the writer analysed the theoretical basis of the international human right to freedom of expression, as well as the limitations imposed on it in the form of censorship. The study tries to investigate means and modes through which the essential qualities that free speech offers to society might be preserved, though not at the cost of societal disintegration. It examines several sociological ideas on liberty, as well as how these ideas would respond to current issues in censorship as a tool of regulating becomes relevant. The writer also does a comparative and historical examination of censoring models from around the world. He stated that the free speech is right guaranteed by the law in a liberal democracy and on the other hand censorship is the process of imposing restrictions on this right. Therefore this phenomenon can be alleged as an unnecessary curb on basic right of people i.e. right to liberty.
10. “The Good Censor: Race, Sex, and Censorship in the Early Cinema by Francis G. Couvares”[10]
Hereby the author talks about the So This is Africa (Columbia, 1933)'s fascinating case reveals that Hollywood's in-house censors and censors both state and local take extreme cinematic abuses with sex and racial norms. This parody of "jungle" films used public attention in a cycle of "primitive" life's fictional and non-fictional representations. These films demanded partial immunity from sex and race taboos and featured "native" women normally unclothed. So that's what Africa goes on. But farcical, its proposals for polygamy, interracial dating, homosexuality and even bestiality have brought an exceptionally big storm among the censors. Cut off by a third and helping the industry to construct the Administration of the Production Code, intended to tighten the screen more carefully, the film nevertheless scandalised many.
11. “The Hindu Right and the Politics of Censorship: Three Case Studies of Policing Hindi Cinema, 1992-2002 by Nandana Bose”[11]
This article discusses about the chronological timeline built on a decade of epitomical communications involving India's Core Film Certification Board, the Ministry of Information & Radio, the Police, the Right-Wing Parties and citizens in the process of censorship of Hindi film in the 1990s.
12. “A study of bans and censorship issues in Indian Cinema by Vijay G.”
The author of the research paper stated that if we compile a list of things that are prohibited in India, we'll find the usual suspects like pornography, homosexuality, and the recent prohibition on beef meat, but the ban on hundreds of films would be an unusual addition to the list. India has recently gained a reputation for being very restrictive when it comes to cinematic freedoms. Aside from facing bans, certain films must also contend with the Central Board of Film Certification's "unjust" censorship policy. The author did this study as an attempt to bring out critical information on censorship concerns and their history, as well as the important legal aspects.
INDEX
Chapters ________ pg. no.
I. Censorship and issues related to it ________________________ 9
1. Definition _________________________________________________ 9
2. The Issues _________________________________________________ 9
3. Movies faced Censorship Issues ________________________________ 9
II. Central Board of Film Certification (CBFC) _________________ 11
1. History of CBFC ____________________________________________ 11
2. Censor Process ______________________________________________ 11
3. International Perspective _______________________________________ 12
III. Cinema and Judicial pronouncement _______________________ 13
1. Cinema and free speech ________________________________________ 13
2. Cinema and freedom of expression _______________________________ 14
3. Judicial pronouncements on Film Certification and Censorship _________ 14
I. Censorship and issues related to it
1. Definition
“Censorship means any sections of books, films, news, etc. that are considered obscene, politically undesirable, or a security hazard are suppressed or prohibited.”
2. The Issue
When it comes to films being banned in accordance with process, there is no particular method. The appropriate constraints provided by Article 19 (2) of the constitution, as well as Section 5(b) of the Cinematographic Act, are said to serve the objective, but they have been misused. Any film that compromises India's sovereignty and integrity, the country's security, friendly relations with foreign countries, public order, decency, or morality, or contains defamation or contempt of court, or is likely to incite the commission of any crime, is not permitted to be screened in India but whether or not all of the films that were banned matched the aforementioned criteria remains an open matter. An example of this can be the film "No Fire Zone: In the Killing Fields of Sri Lanka" was banned because the administration couldn't afford to aggravate their relationship with their Sri Lankan counterparts any further. Apart from the legal permutations listed above, there are numerous other unofficial situations that have resulted in bans.
More than anything else, the dispute has always been over the film's content.
3. Movies faced Censorship Issues
Below there are some movies which faced censorship issues in one or other ways:
i. The biographical film “Bandit Queen” (1994), based on the life of Phoolan Devi, a bandit who subsequently became a member of Parliament, was banned by the Delhi High Court after Devi questioned its veracity.
ii. The Tamil drama film “Kuttrapathirikai” (2007), which was completed in 1993 but was not allowed to be released until 2007 by the CBFC since it featured the killing of Former Prime Minister Rajiv Gandhi as a backdrop.
iii. A court order banned the transmission of "India's Daughter," a documentary on the 2012 gang rape. The film was eventually uploaded to YouTube before being taken down at the request of Indian authorities.
iv. “Udta Punjab” was met with strong criticism from the CBFC since it dealt with the Punjab government's incapacity to control the drug mafia. The picture had to make a stunning 89 cuts in order to get certified. After the High Court heard the case and suggested only one cut, a leaked copy of the film circulated online with a "censor" marking, causing even more controversy.
v. The Tamil Nadu government banned "Dam 999" for allegedly instilling anxiety in the public over the Mullaiperiyar Dam's strength and stability.
vi. The presentation of "Final Solution," a 2004 documentary based on the Gujarat carnage of 2002, was delayed due to fears of sectarian violence. After widespread popular backing, it was eventually allowed to be released.
vii. The film "Madras Café" and "Inam" was banned in Tamil Nadu because it was shot in the backdrop of the Sri Lankan Civil War.
viii. The Hindi comedy play "Santa Banta Pvt Ltd" was banned in Punjab because it depicted Sikhs in a derogatory manner.
ix. The popular Hollywood film "The Da Vinci Code" was banned in Punjab, Goa, Andhra Pradesh, and Tamil Nadu for fear of hurting Christian feelings.
x. The film "The Girl with the Dragon Tattoo" was never released in India due to its explicit sexual content and the refusal of the directors to make the CBFC-recommended changes.
II. Central Board of Film Certification (CBFC)
1. History of CBFC
The Cinematographic Act of 1952 established the Central Board of Film Certification (CBFC). The amendment of 1959 gave the board the authority to certify a picture before it could be shown in public. It was known as the Central Board of Film Censorship until 1983, when it changed its name to the Central Board of Film Certification. The board has the authority under Section 3 (3) (iv) of the Act to refuse to sanction the film's showing in addition to certifying its content. Recently, the board has been under criticism for refusing to allow the screening of recent films like as Bollywood's "Padmavati" (2018), "Lipstick under My Burkha" (2017), and "Udta Punjab" (2016), as well as Hollywood's "Fifty Shades of Grey" (2015).
The subject of restraint was first brought to light in 1959, when a Bengali film titled “Neel Akasher Neechey” was banned for two months due to concerns about political unrest. Since then, the CBFC has proven to be a crucial cog in the increase in the number of films being banned, as it is the responsible authority in the field of cinema.
CBFC is a statutory entity formed for the categorization and regulation of films by the Ministry of Information and Broadcasting, government of India. The Board of the Film Board may review and test the film before public exhibition under Section 4 of the Cinematograph Act of 1952 while the Section 5(A) of the Act establishes different categories for certifying films after a prescribed test. The below are the different categories in which a film is certified:
U (Unrestricted public exhibition).
A. (Restricted to adult audiences).
UA - (Unrestricted public exhibition subject to parental guidance for children below the age of twelve).
S - (Restricted to specialised audiences such as doctors).
2. Censor Process
The CBFC (often known as the "Censor Board") oversees the process, with a maximum of 25 members and 60 members working as an advisory panel to assist and advise the members, who are all appointed by the Information and Broadcasting Ministry. After receiving an application, the Regional Officer will designate a four-member Examining Committee and an examining officer among which 2 members must be women. The committee will watch the video and provide a report with suggestions for changes and deletions. Based on the committee members' reports, the regional officer will certify it as U, U/A, A, or S. If the applicant expresses any dissatisfaction, the applicant will be given a list of recommended adjustments. The censor board must give a certificate for the submitted content within 68 days of receiving the application. This includes the time it takes to make all of the necessary cuts and mutes. To encourage greater transparency, the process has now been made available online. If the applicant is still unhappy with the certification, he or she may appeal to the Revising Committee and further appeals are heard by the Appellate Tribunal before being heard by the court.
Though the board's stance appears to be justified given the film's excessive obscene content, with easy access to pornography via the internet these days, this defence does not sit well with filmmakers. Furthermore, a large number of films that recently received a U rating appear to include forbidden content that the board purportedly cleared with its eyes closed. As despite multiple intimate sequences, the CBFC allowed "Mohenjodaro" without cuts, but took a firm stance against "Unindian," requesting that its intimate moments be deleted. The board gave "U/A" to Bollywood's movie named, "Ram Leela" (2013), a film shot in a violent time period with a lot of kissing sequences, whereas despite modifications, “Shahid,” a biopic of lawyer and human rights campaigner Shahid Azmi, scored a “A.” Coincidently, in actual life, Shahid had defended the film "Black Friday" when it had censorship issues during its release and the film's director went on to make Azmi's biopic.
Also CBFC's most recent list of suggested beeps is shocking as the CBFC requested that the makers of a video about Nobel Laureate Amartya Sen beep the phrases "cow," "Hindu India," and "Gujarat" since it is a reference to the Prime Minister's home state.
3. International Perspective
Censor boards around the world take varied approaches to films. The CBFC in a neighbouring nation like Pakistan is quite strict when it comes to portraying its country and Muslims in films, which has resulted in the ban of many Indian films such as "Baby" (2015) and "Haider" (2014), etc. The United States and the United Kingdom, on the other hand, have a more simple and straightforward method for rating films.
The Motion Picture Association of America (MPAA) maintains a six-type rating system, which includes G – General Audience; PG – Parental Guidance Suggested as Content May Not Be Appropriate; PG-13 – Not suitable for children under the age of 13; R – Restricted to people above the age of 18, however minors under the age of 17 may accompany an adult; NC-17 – No children who are 17 years old or younger; NR (or) UR - Not Rated or Unrated for movies not submitted for rating that can also be played in select theatres. The British Board of Film Classification (BBFC) uses the same U, PG, 12A, 15, 18, and R 18 classification system for films that can only be seen in licenced adult cinemas.
They normally proceed depending on the version they receive from the crew, rarely demanding cuts other than only recommending cuts and rate films accordingly, leaving it up to the filmmakers to decide their fate. Not that they are indulgent in letting go of anything that comes their way, but it is only fair to say that they choose what they get and leave it up to the people to pick what is good or bad for them, hence lessening censorship difficulties. Hence, strong sexual content and excessive violence are disapproved upon by all censor boards around the world.
III. Cinema and Judicial pronouncement
1. Cinema and free speech
The art of colourful moving images has been termed as cinema or motion picture. Cinema is an artistic expression of ideas, stories, and often viewpoints, sometimes inspired by reality and often set to music, with the goal of enthralling, enchanting, or just entertaining the audience. Since its inception, cinema has been regarded as the most practical tool of expression. It is viewed as the medium through which the broader aspect of people and their lives is depicted on a screen, which includes many aspects of society such as social, economic, political, spiritual, or religious, all of which have a significant impact on the nation's functioning.
2. Cinema and freedom of expression
Speech, art, literary labour, music, and other forms of expression might be considered a part of the larger conception or benevolent idea of free thought. Free cinema can be considered as a touchstone of freedom of speech because it is an intensive and powerful medium for expressing free ideas and thoughts because it allows for a deeper understanding of cultural ideals and current trends, ultimately serving as a vehicle for transformation and revolution, One might easily associate the word "free cinema" with a platform where ideas can flow freely and without constraint of any kind. Freedom of expression, in its broadest sense, can embrace a wide range of outlets through which it might be expressed.
Part III of the Indian Constitution, which enshrines fundamental rights, considers freedom of speech and expression to be one of the most sacred. All citizens have the right to freedom of speech and expression, according to Article 19(1) (a) of Part III of the Constitution. Various judicial decisions are discussed later in this article to determine whether cinema, as a method of expression, is within the scope of such constitutional protection, as Article 19(2) imposes reasonable constraints on the freedom provided by Article 19(1) (a). Reasonable restrictions on these rights can be imposed on the basis of national security, cordial relations with other states, public order, decency, or morality, or in cases of contempt of court, defamation, or incitement to commit an offence.
In India, cinema is regulated by the Cinematograph Act, 1952, which establishes rules for film certification to determine on what grounds films must be certified; these standards come within the context of reasonable limitations. This legislation contains measures for regulating film exhibition, and Section 3 of the act established the Central Board of Film Certification (CBFC), a regulatory agency tasked with certifying films for public display.
3. Judicial pronouncements on Film Certification and Censorship
In the case of K.A Abbas V. Union of India before the Hon'ble Supreme Court of India, various laws regarding cinema certification and censorship were set under the Cinematograph Act in 1983, which was challenged as infringing Article-19(1)(a) of the Constitution. The appellant contended that such provisions, as stated in several sections of the Act, such as Section 5(1)(B), Section 4, and the CFBC's refusal to issue his film a certificate without multiple edits, are in plain violation of the fundamental right to freedom of speech and expression. In this decision, the Supreme Court supported cinema censorship on the grounds that films must be treated independently from other kinds of art and expression because a motion picture might elicit more intense emotions than any other kind of art. As a result, a film can be restricted for the reasons stated in Article 19(2) of the Constitution. The court determined that censorship is a permissible exercise of power in the sake of public morality and decency, based on the standard of reasonable restriction.
However, in the case of S. Rangarajan v. P. Jagjivan Ram, the Supreme Court upheld freedom of expression by overturning a Madras High Court decision that had revoked a U certificate for the film "Ore Oru Gramathille" on the grounds that the film, which dealt with critical aspects of government reservation policy as a theme, could cause public unrest, resulting in law and order breakdown in the state of Tamil Nadu. When the case was appealed to the Supreme Court, it was decided that "it is the State's duty to preserve freedom of expression because it is a liberty secured against the State." The State cannot claim that it is unable to deal with the hostile audience issue.” While making this comment, the Court also stated that the State has no right to claim that it is unable to cope with hostile audience situations.
In the case of Life Insurance Corporation of India v. Prof. Manubhai D. Shah, a documentary film on the “Bhopal Gas Tragedy,” which also won a national award, was selected to be screened on Doordarshan, which it refused, citing the reasons that the case for the tragedy is still pending with respect to victim compensation, and many political parties have raised various questions on the subject. The Supreme Court said, “Merely because it is critical of the State Government is no justification to refuse the film selection and publication, similarly, the pending compensation claims do not render the topic sub-judice, thus excluding the entire film from the community.” In this instance, the court also stated that a citizen has the freedom to publish, circulate, and communicate his or her opinions in order to shape public opinion on critical issues of national importance, and that any attempt to restrict this liberty would be in violation of Article-19(1) (a).
After seeing so much judicial intervention in its efforts to protect freedom of speech and expression, the government or executive enacted Section-6(1) of the Cinematograph Act,1952, which gave the board the power to overturn an appellate tribunal's [FCAT] decision in matters of film exhibition or regulation but In the landmark case of Union of India v. K.M Shankarappa, the Supreme Court declared such legislation unconstitutional and a violation of the Basic Structure Doctrine, noting that the executive must obey all judicial orders, and that a tribunal comprised of a retired High Court judge and established by statute to perform quasi-judicial functions has its decision binding on the executive, and that the government may apply for review but it cannot review or revise judicial order.
Although there have been many cases or judicial precedents that have supported cinema as a form of free speech, the most recent case in which the judiciary has reprimanded or warned the Central Board of Film Certification (CBFC) on its infringement of such rights is the controversy surrounding the film “Udta Punjab,” which is based on the drug problem in Punjab. In addition to refusing to certify the film, the board recommended nearly 13 cuts as a requirement for certification. The Bombay High Court, however, criticised the Central Board of Film Certification for its actions and poor handling of the situation in response to the filmmaker's appeal. The Court made the crucial conclusion that the Board does not always have the authority to censor films. The Cinematograph Act does not contain the word censor. The board has the authority to alter the picture, but it must do so in accordance with the Constitution's guarantee and Supreme Court orders. It can be seen that the board has erroneously expanded its powers, which were originally intended to be limited to the certification of films for exhibition exclusively, to include the power to censor as well. Citizens' rights may be jeopardised as a result of the board's attitude, which is frequently politically driven.
TABLE OF CASES
1. K.A Abbas V. Union of India[12]
2. S. Rangarajan v. P. Jagjivan Ram[13]
3. Life Insurance Corporation of India v. Prof.Manubhai D. Shah[14]
4. Union of India V. K.M Shankarappa[15]
5. Anand Patwardhan v. Central Board of Film Certification, 2003
6. Sree Raghavendra Films v. Government of Andhra Pradesh, 1995
REFERENCES
DATABASES
1) JSTOR
2) SCC Online
3) Manupatra
4) Hein Online
JOURNALS
1. Censorship in India vis-à-vis freedom of speech: Comparison of the extent of censorship laws in India and Abroad by Priyanka Ghai and Dr. Arnind P Bhanu
2. Censorship by George Anastaplo
3. Censorship by Elizabeth R. Purdy
4. Censorship and Freedom of Expression in the Age of Facebook by Benjamin F. Jackson
5. The Good Censor: Race, Sex, and Censorship in the Early Cinema by Francis G. Couvares
6. The Hindu Right and the Politics of Censorship: Three Case Studies of Policing Hindi Cinema, 1992-2002 by Nandana Bose
WRITER:
NAME: SANKET DHULL
COLLEGE: Symbiosis Law School, Hyderabad
[1] Priyanka Ghai & Dr. Arnind P Bhanu, Censorship in India vis-à-vis freedom of speech: Comparison of the extent of censorship laws in India and Abroad (1994) [2] George Anastaplo, Censorship (2017) [3] Divya Rai, Laws governing censorship of movies in India (2021) [4] Elizabeth R. Purdy, Censorship (2002) [5] Satyam Rathore, A Critical Overview of censorship in Indian Cinema in the Light of Role of CBFC, Bharati Law Review (2016) [6] Boyd, B., FILM CENSORSHIP IN INDIA : A "REASONABLE RESTRICTION" ON FREEDOM OF SPEECH AND EXPRESSION (1972) [7] Benjamin F. Jackson, Censorship and Freedom of Expression in the Age of Facebook (2014) [8] Volga, To Censor or Not to Censor: Film and Public Policy, Economic and Political Weekly (2021) [9] Sen, S., RIGHT TO FREE SPEECH AND CENSORSHIP: A JURISPRUDENTIAL ANALYSIS. Journal of the Indian Law Institute, (2014) [10] Francis G. Couvares, the Good Censor: Race, Sex, and Censorship in the Early Cinema, 7 The Yale Journal Of Criticism 223 (1994). [11] Nandana Bose, The Hindu Right and the Politics of Censorship: Three Case Studies of Policing Hindi Cinema, 49 Cinema Journal 67 (2010). [12] 1971 AIR 481, 1971 SCR (2) 446 [13] 1989 SCR (2) 204, 1989 SCC (2) 574 [14] 1993 AIR 171, 1992 SCR (3) 595 [15] ILR 1990 KAR 4082
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