Bombay High Court Issues Notice On Plea By Filmmaker Challenging CBFC's Objection To Use Of 'Janki & Raghuram' In Movie

The Bombay High Court on Monday issued a notice to the Central Board of Film Certification (CBFC) asking it to respond to the petition filed by the makers of the Chhattisgarh based film 'Janki' which is objected to because of its title and also to the names of the lead actors in the film.

The CBFC, according to the makers, have objected to the title of the film 'Janki' as it is the name to Goddess Sita. The central agency has further objected to the name of the male lead in the film which is 'Raghuram.' The film revolves around the lead characters Raghuram and Janki and their relationship amid huge action.

A division bench of Justices Revati Mohite-Dere and Sandesh Patil has asked the CBFC to respond to the petition by October 6.

The film starring actors Dilesh Sahu and Anukriti Chouhan is directed by Kaushal Upadhyay.

Notably, the film was initially made in Chhattisgarhi language and later on made for release in Hindi and accordingly its trailer was released on CBFC's approval on May 16, 2025. Subsequently, an application was made by the makers for the film's certification and on June 10, 2025 the CBFC informed the producers that the film has been successfully screened and its Examining Committee has recommended an "UA 16+" certificate along with certain modifications and deletions.

Besides the various cuts and modifications, the makers were asked to alter the film's title and also the names of the two leads - Janki and Raghuram, citing its guidelines to ensure no religious or social sentiments are hurt. However, the makers questioned the modifications recommended by the CBFC arguing that it is an attack on their fundamental right to free speech and expression.

"The objections raised by the CBFC in its notices dated Junem10, 2025 and July 15, 2025 are arbitrary, unreasonable, and unsustainable in law. The directions for excisions and modifications as contained therein are devoid of cogent reasoning and lack any statutory foundation under the Cinematograph Act, 1952 or the Rules framed thereunder. The CBFC have failed to apply its mind to the context and content of the scenes objected to, and have instead relied upon generalised and baseless assumptions. The impugned objections, being without justification, amount an infringement of the Petitioner's right to freedom of speech and expression guaranteed under Article 19(1)(a) of the Constitution of India," the plea states.

The makers have contended that now the title or the names of the film cannot be altered as the same has already been approved, registered, and publicised in the market. Despite such a clear stand of the makers, the CBFC has failed to come up with a proper response to the makers.

"Unless the impugned objections are quashed and set aside, we will suffer grave and irreparable prejudice, including loss of the scheduled release window, disruption of distribution arrangements, impairment of reputation and goodwill, and an adverse impact on his artistic freedom, none of which can be adequately compensated in monetary terms. The directions of the CBFC requiring alteration of the very title of the film and raising objections which are arbitrary, baseless, and devoid of statutory foundation, cannot be sustained in law. Compliance with such unjustified objections would not only cause severe financial loss to the Petitioner but would also undermine his creative work and destroy the substantial investment already made in the publicity and promotion of the film," the plea reads.

The makers have also relied on a recent judgment of the Kerala High Court in the case of M/s Cosmos Entertainments v. Regional Officer, CBFC (Janaki vs State of Kerala Film), wherein it has been held that compelling a filmmaker to delete or change the word 'Janaki' from the title or dialogues amounts to an unconstitutional infringement of the right to freedom of speech and expression guaranteed under Article 19(1)(a) of the Constitution of India.

The bench is likely to take up the matter for further hearing on October 6.

Appearance:

Advocates Hemant Shukla and Veer Kankaria appeared for the Film Makers.

Case Title: M/S N Mahi Films Production vs Central Board of Film Certification