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S. Rangarajan vs. P. Jagjivan Ram (1989): Safeguarding Freedom of Expression in Cinema

In the annals of India’s judicial history, the case of S. Rangarajan vs. P. Jagjivan Ram stands out for its robust defense of the freedom of speech and expression, especially concerning films. This case centered around the movie “Ore Oru Gramathile”, which was denied a certificate for public exhibition by the Film Certification Appellate Tribunal due to its portrayal of reservation policies. Here’s a deep dive into the case and its significance.

Background of the Case: The film “Ore Oru Gramathile” revolved around the theme of reservations, a sensitive issue in India. The Central Board of Film Certification (CBFC) initially granted the film a certificate for exhibition, but it was subsequently revoked by the Film Certification Appellate Tribunal following protests and complaints. The key argument against the film was that it could potentially incite public disorder.

Key Aspects of the Judgment:

  1. Freedom of Expression: The Supreme Court emphatically reiterated that freedom of speech and expression is of paramount importance and forms the foundation of any democratic society.
  2. Artistic License: The Court recognized that films are a powerful medium of communication and expression. Directors and artists must be granted a certain degree of freedom to portray societal realities, even if they are controversial.
  3. Risk of Public Disorder: The Court held that the apprehension of public disorder cannot be used as a reason to stifle freedom of expression. If the standard of judging a film is set by the most sensitive viewer, it would lead to a gross violation of the freedom of expression.
  4. Restoration of Exhibition Certificate: The Supreme Court reversed the Tribunal’s decision and reinstated the certificate granted by the CBFC, allowing the film to be exhibited.

Critical Analysis:

  • Protection of Artistic Freedom: The judgment is a testament to the Court’s commitment to protect artistic freedoms. By focusing on the intrinsic value of films as a medium of expression, the Court reinforced the notion that filmmakers shouldn’t be unduly muzzled due to societal sensitivities.
  • Distinguishing Dislike from Disruption: The Court’s argument that a distinction must be made between a film’s potential to be disliked and its potential to disrupt public order is particularly noteworthy. This sets a high bar for censorship.
  • Potential for Controversy: While the judgment stands as a bulwark for freedom of expression, it also raises questions about where the line should be drawn. When does a portrayal become too controversial or potentially harmful? This remains a subjective area.

Conclusion: S. Rangarajan vs. P. Jagjivan Ram is a landmark case in India’s cinematic and legal history. The Supreme Court, through this judgment, sent a clear message about the importance of preserving the freedom of speech and expression. It reiterated that a film should be an open canvas, reflecting societal issues without undue interference, even if it treads on contentious grounds. The case remains a beacon for filmmakers, assuring them that their right to express will be guarded against undue censorship.

Shivendra Pratap Singh


High Court Lucknow

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