S. RANGARAJAN ETC. versus P. JAGJIVAN RAM & ORS.

S. RANGARAJAN ETC. versus P. JAGJIVAN RAM & ORS.

Freedom of expression in film cannot be restricted except for grounds legally enumerated in Article 19(2). Law and order threats or controversy over government policy are not sufficient grounds for restricting films. The High Court's revocation of the 'U' certificate was unjustified as the statutory bodies followed guidelines and the theme was constitutionally permissible.

Parties
Appellant – Producer: S. Rangarajan; Appellant: Union of India; Respondents: P. Jagjivan Ram & Ors.
Jurisdiction
India
Judgment Date
30 March 1989
Procedural Posture
Civil Appeal / Appeal by Special Leave From Madras High Court Judgment Revoking 'u' Certificate
Outcome
Appeals allowed; High Court judgment reversed; writ petitions dismissed.
Legal Topics
Freedom of Speech and Expression, Cinematograph Certification, Reasonable Restrictions, Law and Order, Reservation Policy
Constitutional Law Media Law Administrative Law Freedom of Speech and Expression Cinematograph Certification Reasonable Restrictions Law and Order Reservation Policy

Case Brief

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Parties

S. Rangarajan

Appellant – Producer

Union of India

Appellant

P. Jagjivan Ram & Ors.

Respondents

Procedural Posture

Civil Appeal / Appeal by Special Leave From Madras High Court Judgment Revoking 'u' Certificate

Legal Issues

  1. 1 Whether revocation of the 'U' certificate for 'Ore Oru Gramathile' was valid under the Constitution and Cinematograph Act
  2. 2 What are the reasonable limits on freedom of expression under Article 19(1)(a) and 19(2)?
  3. 3 Does threat of law and order justify restriction of expression?

Ratio Decidendi

Freedom of expression in film cannot be restricted except for grounds legally enumerated in Article 19(2). Law and order threats or controversy over government policy are not sufficient grounds for restricting films. The High Court's revocation of the 'U' certificate was unjustified as the statutory bodies followed guidelines and the theme was constitutionally permissible.

Court Disposition

Appeals allowed; High Court judgment reversed; writ petitions dismissed.

Orders

  • The judgment of the Madras High Court revoking the 'U' certificate is set aside.
  • The writ petitions by the respondents are dismissed.