No Certification for Film Mocking Religions, Inciting Hatred in Secular Society: Delhi HC on Masoom Kaatil

While denying certification to the Hindi film Masoom Kaatil, the Delhi High Court held that certification cannot be granted to a film that ridicules religions, incites hatred, or threatens social harmony in a diverse, secular society.

Justice Manmeet Pritam Singh Arora was dealing with an appeal filed by filmmaker Shyam Bharteey, challenging the refusal of certification by the Central Board of Film Certification (CBFC) for public exhibition of his film Masoom Kaatil.

The CBFC, while refusing to grant a certificate, reasoned that the film justifies vigilantism, is communal in its portrayal, depicts gruesome violence and killings, shows human cannibalism, uses expletives, portrays extreme violence on animals, contains communal and caste remarks, and denigrates religions in a manner likely to incite further violence and disrupt social norms.

Upholding the ban, Justice Arora observed that in the film the protagonists take the law into their own hands without consequence. “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 noted.

“When such dangerous ideas are combined with graphic scenes of killing and cannibalism, the subject matter film could seriously upset public peace and encourage others to act violently, putting the safety of society at risk,” the judgment added.

The film portrays the journey of Anirudh, a sensitive boy from a devout vegetarian family deeply affected by animal cruelty. Traumatized by his grandfather’s death and influenced by the Garuda Purana, he comes to believe slaughtered animals may be reincarnations of loved ones. Haunted by butcher shops, he secretly develops a lethal chemical and begins targeting butchers.

He later meets Vedika, a classmate whose hatred for butchers surpasses his own. Persuading Anirudh that offenders deserve equal pain, she masterminds their killings and disposal of bodies. The narrative ultimately reveals Vedika as the central force, driven by a radical mission to eradicate butchers and poultry farm owners nationwide.

The Court noted that the appellant failed to persuade it that the reasons cited by the Examining Committee and the Revising Committee in refusing certification were unreasonable or contrary to the contents of the film. Instead, the filmmaker had merely urged that the film be granted an ‘A’ certificate with suitable cuts.

Rejecting this plea, the Court held, “A perusal of the contents of the report of the Examining Committee and the impugned order of the Revising Committee shows that the content of the subject matter film is excessively and unnecessarily violent, gruesome in its portrayal without any redeeming factors and therefore, not fit for public exhibition. The exhibition of unchecked gore content as shown in the subject matter film is far from promoting social values and would instead brutalize minds and normalize lawlessness.”

Court further recorded that the film contains not only violent content against humans and animals but also insulting references to communities, derogatory remarks about religions, and caste-based/communal statements. “Such depictions fall within the express prohibitions of Rules 2(i), (iii), (iv), (vii) and (xiii) of the 1991 Guidelines, which prohibit any film likely to promote communal disharmony or offend religious sentiments. In a diverse, secular society, certification cannot be granted to a film that ridicules religions, incites hatred, or threatens social harmony,” the Court emphasized.

Another concern raised by the Court was the depiction of minors as protagonists engaging in gore, lawlessness, and anti-social acts. “The film fails to condemn or correct such behavior, thereby risking the morals of young viewers. This portrayal violates Rule 2(iii)(a) of the 1991 Guidelines, which prohibits films from corrupting the morality of children and susceptible audiences, and impermissibly glamorizes juvenile wrongdoing,” the Court said.

On the claim of artistic freedom, Justice Arora ruled, “The freedom of artistic expression cannot be accepted in the teeth of the statutory framework, i.e., the Act of 1952. Article 19(1)(a) of the Constitution of India itself subjects Freedom of Speech and Expression to reasonable restrictions on grounds of decency, morality, public order, and incitement to offence. The content of the subject matter film, as discussed above, traverses all these prohibitions."

The Court held that Masoom Kaatil was fundamentally incompatible with the Cinematograph Act, 1952 and the 1991 Guidelines, and accordingly dismissed the appeal.

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

Order Date: 10 September 2025

Bench: Justice Manmeet Pritam Singh Arora