P&H High Court Clears Release Of Film On Lawrence Bishnoi, Orders Title Change

The Punjab and Haryana High Court has cleared the release of a Zee5 film supposedly related to Lawrence Bishnoi after setting aside the Centre’s advisory opposing its release, while simultaneously directing the makers to change the title to ensure that it does not contain the words “Lawrence Bishnoi” or “Punjab.”

The Court observed that the movie, upon viewing, neither glorified gangster culture nor revolved around a single gangster, but instead conveyed a message against gun culture and organised crime.

Holding that the apprehensions raised by authorities were insufficient to justify a pre-release restraint on speech, the Court paved the way for the release of the film subject to modification of its title.

Justice Jagmohan Bansal passed the order in a petition filed by Zee Entertainment Enterprises Limited challenging communications dated April 23 and April 24, 2026 issued by authorities advising the OTT platform against releasing the web series/film titled “Lawrence of Punjab”, which was slated for release on April 27.

While quashing the impugned advisory, the Court directed that the title of the film be suitably altered so that it does not include the words “Lawrence Bishnoi” or “Punjab,” observing that such terminology could create misleading connotations.

The dispute arose after the Central Government, acting on inputs received from Punjab Police and security agencies, advised against the release of the film citing concerns relating to public order, glorification of gangster culture and possible influence on impressionable youth.

Authorities had contended that the content, inspired by the life and notoriety of gangster Lawrence Bishnoi, could adversely affect law and order and contribute to the growing culture of organised crime in Punjab.

According to the petitioner Zee Entertainment Enterprises Limited, the impugned communications effectively amounted to an unlawful pre-publication restraint on its fundamental right to freedom of speech and expression guaranteed under Article 19(1)(a) of the Constitution.

The company argued that the authorities had neither invoked any statutory mechanism nor followed any due process prescribed under law before issuing directions restraining the release of the film.

The petitioner further contended that the documentary-style film was based entirely on material already existing in the public domain, including media reports, publicly available footage and factual accounts.

It asserted that the film neither incited violence nor glorified criminal conduct, and that the apprehensions raised by the State were speculative and lacked any proximate nexus with public order concerns as required under Article 19(2) of the Constitution.

During the proceedings, the State of Punjab strongly defended the advisory and opposed the release of the film in its existing form.

Advocate General for Punjab Maninderjit Singh Bedi argued that such content had the potential to influence young viewers and vulnerable sections of society by normalising or indirectly glamourising gangster culture.

The State maintained that Punjab, owing to its unique geographical and social vulnerabilities as a border State, remained particularly sensitive to issues involving organised crime, illegal arms circulation and narcotics networks.

The State further informed the Court that it had already blocked more than 2,600 online links allegedly promoting gangster culture and glorifying Lawrence Bishnoi.

It argued that unrestricted dissemination of such content through OTT platforms posed a tangible threat to public order and could exacerbate existing law and order challenges within the State.

In its reply before the Court, the Punjab Government submitted that depiction of criminal networks and gun culture carried a heightened risk in a sensitive State like Punjab.

The State asserted that the film had the potential to instigate and influence impressionable youth and adversely impact public order and security.

Senior Advocate Dhiraj Jain, appearing on behalf of the Union Government, defended the Centre’s advisory and argued that the Central Government was empowered under the Information Technology Act to issue such advisories.

He submitted that the Union had exercised similar powers in the past and that security agencies had raised concerns regarding the portrayal of a notorious gangster figure in the film.

According to the Union, such portrayal could potentially influence witnesses and ongoing criminal proceedings apart from impacting young viewers.

Despite these concerns, the Court appears to have accepted the petitioner’s contention that restrictions on speech and expression cannot be imposed merely on the basis of speculative apprehensions.

The Court’s observations indicate that it found no direct glorification of gangster culture after viewing the film. Instead, the Court noted that the movie projected an anti-gun and anti-crime message rather than celebrating criminality.

At the same time, the Court deemed it appropriate to direct modification of the title to avoid associating the film directly with Lawrence Bishnoi or Punjab.

The direction is significant as it reflects a balancing approach, protecting freedom of expression while simultaneously addressing concerns relating to public perception and potential sensationalisation.

Case Title: ZEE Entertainment Enterprises Limited v. Union of India

Bench: Justice Jagmohan Bansal