A CRITICAL ANALYSIS OF THE CINEMATOGRAPH ACT,1952 AND FACETS OF CINEMATOGRAPHY WITH SPECIAL EMPHASIS ON ITS CONSTITUTIONAL AND LEGAL ASPECTS. BY - NEHA CHATURVEDI
A CRITICAL ANALYSIS OF THE CINEMATOGRAPH ACT,1952 AND FACETS
OF CINEMATOGRAPHY WITH SPECIAL EMPHASIS ON ITS CONSTITUTIONAL AND LEGAL
ASPECTS.
AUTHORED BY
- NEHA CHATURVEDI
ABSTRACT
Freedom of press and media is
vital for democracy which assists in formulating deliberations
and public opinion. The strength of a democracy lies in its principles of
freedom of thought and expression. The Cinematograph Act,1952 was promulgated
with an objective of regulating the certification and exhibition of films and
categorically classifying them based upon their content . But, what happens
when independent journalism, novelty and creativity are throttled and
exhibition of films curtailed owing to unguided,unfettered arbitrary decisions
of authorities?The question which needs to be answered in the modern times is ,
whether the balance which is sought to be maintained between individual rights
and public interest is scrupulously maintained ? What are the means and methods
by which the executive impinges upon the autonomy of the competent statutory
authorities ? What are the constitutional, legal and ancillary questions
involved which pertain to a virtual abrogation of powers of regulatory bodies ?
This research paper seeks to answer these questions,descriptively as well as
analytically.
Although public interest cannot be overlooked and towards that end , the
legal regulatory framework by bestowing upon powers on statutory authorities
regarding certification of films and setting up of advisory panels, has
substantially conformed to the concept of reasonable restrictions under Art
.19(2), but an unjustified intervention by the executive in the film industry
has a high probability of doing more harm than good. Media and entertainment
are robust pillars of democracy involving free flow of ideas encompassing
varied mindsets and contribute heavily in terms of revenue. An harmonious
construction of these two conflicting interests shall supplement free flow of
ideas, information and thereby uphold individualism with notions of collectivism
running throughout like a golden thread. This research paper makes an attempt
to critically analyse the Cinematograph
Act,1952 with an objective of
reinforcing democratic values and traditions.
Keywords: Press freedom, Film certification, reasonable restrictions, democracy,
entertainment
1 INTRODUCTION
Cinema is one such platform which
paves the way for propagation of ideas, social,political,economic,cultural
issues and enhances the ability of the audience to formulate informed
decisions. Cinema serves a multitude of functions.It is not only a source of
entertainment and hero worship , but also a vital tool to express novel and
creative ideas as well as express dissenting views upon debatable subject
matters.Individual and collective perceptions about society and burning issues
are shaped by cinema. Encompassing a plethora of languages, it caters to the
recreational needs of a wider audience thereby comprehensively engaging them as
active participants in the affairs of state.Certain provisions in the
Cinematograph Act have time and again been regarded as draconian by
stakeholders in the filmmaking industry. There have been umpteen such cases
where the whims and fancies of the political regime were allowed to penetrate
this vast industry, subjecting them to vague and unreasonable restrictions in
the garb of public interest. Where such an ubiquitous art form is restrained
within ill defined contours and excessive surveillance of the executive
pervades its smooth exhibition, there lies unjustified curtailment of freedom
of speech and expression showcasing dictatorial tendencies.
India’s ranking in the World Press
Freedom Index ,2023 slipped to 161 out of 180 countries. Such a poor
performance indicates unnecessary curbs on free flow and exchange of
information. Drawing a comparison, many South Asian countries fared better in
terms of press freedom than India, and yet India is regarded to be the mother
of all democracies in the world. Press freedom including fearless exhibition of
films bolsters pluralistic views on one hand and enhances tolerance and
integration amongst communities on the other. The Cinematograph Act, promulgated
with an objective of regulating the certification of films, has values of
colonial mindset deeply ingrained and reflected on a bare perusal of its text
and impact. A robust entertainment
industry not only elevates the reputation of a country on an international
level, but it also fosters cultural exchanges and linkages between various
states. The Film industry having such an expanse has social, economic,
political,cultural impacts over its targeted audience , leaving space for
critical and reflective thinking .
The amendments to cinematograph Act
have engulfed screen players, directors,producers, actors in a state of chaos
,confusion and uncertainty. Allegations have been made by the political
community that these platforms have been endorsed for the purpose of lampooning
them. But such averments lack form and substance. Disparate views and opinions
are the backbone of a democracy, and cinema invigorates such incommensurate
impressions. A film which has been cleared for exhibition by the censor board,
cannot be denied an audience owing to law and order issues in the state. Such
sweeping responsibilities are that of the concerned Government and measures in
the form of preventive and mitigative should be espoused rather than abridging
the exhibition of film. A convivial societal ambience provides the necessary
impetus for the seamless exhibition of film thereby boosting democratic norms,
values and traditions.
Research methodology
The researcher has adopted a
doctrinal research methodology in the process of formulating the study . An
analytical approach has been undertaken by the researcher for the purpose of critically
examining the multifaceted aspects of cinematography and an interpretation of
the Cinematograph Act,1952. In the pursuit of understanding reasons behind
opposition from the film industry to certain provisions of the Cinematograph
Act and relevance of cinematography , the researcher has also taken recourse to
the descriptive research methodology .
Constitution of India ,Legislations , subordinate legislations, and
judicial decisions were relied upon as primary sources for the purpose of data
collection & websites , journals , newspaper reports and e-books were
relied upon as secondary sources.
Research Objectives
- To undertake a multifaceted
analysis of Cinematography.
- To analyse the reasons for poor
performance of India at the World Press Freedom Index, 2023.
- To critically analyse the
Cinematograph Act, 1952 and its amendments thereto.
- To formulate solutions for
strengthening the inalienable right of freedom of speech and expression
through cinema.
1.1 Cultural Aspects of Cinematography
Cinema is reflective of the
collective mindsets of the society and responds to their cultural and moral
values. Garnering public support in the form of a value based, needs based and
behavioural based approach, it envisions a normative system and feelings of cultural
solidarity.People relate to films in their way of life and evaluate them based
on their cultural tendencies.Such is the dynamic relationship between them
,that to separate them in strict watertight compartments without any scope for
overlapping, would often render them meaningless and ineffective. The cultural
attitudes and adherence to social customs have a direct and proximate link with
movies being cast and exhibited[1].
Therefore, the cultural aspects are inextricably woven around cinematography
and play a profound role in shaping one’ personality. Significance of history
is also highlighted through the platform of cinema ,which not only reflects our
current trends but also informs us of diverse and distinct cultural
manifestations in the past[2]. Such is
the power of cinema, that cultural pluralism is comprehended utilising a
functional- liberalism approach building resilient societies.
When arbitrary and unguided
restraints are imposed on the film industry and unreasonable modifications and
cuts authorised, people are devoid of an opportunity to appreciate cultural
linkages of the past and hence denied their vital right to know and participate
in the cultural process of a state. The International community is also
deprived of a perspective of a wider horizon reflecting the divergent cultural
values of a society and state ,thus indirectly
hampering soft diplomacy of a nation. A robust and independent film
industry portrays and solidifies ethnocultural values of a group thereby
promoting tolerance amongst groups and communities[3].
In the era of globalisation and liberalisation , showcasing the cultural
heritage and cultural dominance of India through the medium of cinema will also
foster cultural exchanges in the form of tourism and its allied sectors.
Therefore it is evident that from a
cultural standpoint ,it is in the interests of a society and progress of a
nation-state, that cinema continues to depict artistic expressions and cultural
variations despite there being
tendencies displayed by the institutional machinery to curb such a free
depiction resorting to mechanisms which are neither legitimate nor
proportionate to the object sought to be achieved.
1.2 Economic Aspects of Cinematography
Film industry is assessed to be one
of the finest sources of revenue for the purpose of GDP of a country. The vast
array of services provided by cinema to its consumers heavily contributes to
revenue generation and consequent economic growth of a country. Contracts
involving exorbitant pecuniary interests are the source of employment
generation and enhance the standard of living of many such workers engaged
indirectly in serving the industry[4]. The
trickle down approach adopted by this industry distributes its benefits
equitably rendering a multiplier effect ,thus indirectly benefiting other
sectors .
Unfettered discretionary power of the
executive in defining the limits of restrictions according to facts and
circumstances of a case on flimsy grounds, hampers economic growth of this much
cherished industry leading to job losses and a sense of despair. The outright
banning of a film , leaves the entire industry in a sense of despair as they are
unable to recover the costs of production, let alone accrual of profits. Also
such frequent bans lead to apprehensions in the minds of investors which
ultimately deteriorates financial soundness of the entire system involved[5].
Having understood the complexities
involved in such vexatious actions adopted by the state, it is imperative to
acknowledge the repercussions involved when such hasty administrative measures
are taken and espouse a nuanced understanding of the same.
1.3 Socio- Political Aspects of Cinematography
Cinema is regarded as representing
innumerable socio-political issues pervading a defined time frame and area.
Social issues like poverty, rising crime rate,rampant and unplanned
industrialization, urbanisation and encroachment, illiteracy, extremism ,
radicalisation and terrorism , unemployment , state of affairs pertaining to
education and healthcare services,poor infrastructure , pollution, etc. are
closely related to policies , programmes and interventions of the Government.
Filmmaking dedicated to the cause of a socio-political issue , will certainly
be met with stiff resistance as there are speculations about societal unrest
and ideological considerations being challenged . In such a scenario, the role
of cinema is regarded to be significant in the ways in which reality is
depicted and portrayed. Also, the
concepts of social hierarchies, social mobility , forced and bonded labour ,
discrimination , untouchability , denial of equal rights and opportunities are
showcased with their intricate details[6].
If such is the case, then orders of modifications and cuts in a particular
film, renders it less effective with its ultimate message compromised.
The other key issue plaguing a state
is corruption in every sphere which jeopardises the progress of a nation.
Exposing the various means and methods of corruption by seeking transparency
and accountability, cinema is an appropriate platform to assess the on-ground
situation and devise robust legal frameworks in order to tackle this ever
growing menace. The proletariat are apprised of their political rights and
duties in a democracy. Active participation in the decision making process
along with demands pertaining to reforms in various governance models , shapes
the political consciousness of a society[7].
Owing to power politics , there are scores of cases where censorship is brought
into service to suppress associations and demonstrations questioning the
legitimacy of a Government. Blocking access to information owing to vested
interests in the garb of classifying them as political gimmick, hinders
political and social transformation[8].
The close link between executive
power and film certification is at its zenith when bureaucrats are appointed as
Chairman and members of the Central Board of Film Certification. The question
which comes into play is,if there is any autonomy bestowed upon the board to
take objective and independent decisions? If the answer is in the affirmative ,
questions arise relating to the power of the Central Govt. to review, reassess,
revise and overturn such independent decisions diluting the concepts of
separation of power and principles of natural justice. Such colourable exercise
of political power fosters partisan decision- making, enabling authorities to
circumvent the provisions of law .
2. Constitutional and Legal Aspects of The
Cinematograph Act,1952.
An analysis of the legal aspects of
the Cinematograph Act,1952 reveal that many provisions of the statute are
loosely defined , leaving scope for wider interpretation by the administrative
machinery. The first legal aspect is, the advisory panels constituted under
Sec.5[9] of the
Act. The appointment of advisory panel officers is left at the sole discretion
of the Central Govt.It mandates that such officers who are ‘in the opinion of
Central Govt,qualified to judge the effect of film on the public’. It is clear
that such a wide connotation, leaves ample scope for the advisory panel members
functioning under the dictates of the Central Govt. without due application of
mind and reasoned judgement. There is every possibility that the allowances ,
fees and terms of condition of service of panel members are modified to their
disadvantage by those in power, in order to achieve desired results as panel
members are not entitled to salary. Also, association of regional officers for
the purpose of examination of films , is also determined by the Central Govt.
Therefore , these panels can actually be regarded as puppet institutions of the
Government , as right from their appointment and distribution of business to
budgetary allocations made towards their functioning , these panels have no
autonomy in their day to day functioning and decision making. Another lacuna
is,failure to provide for the procedures of advisory panels for discharging their
functions. Yet another constitutional and legal disparity which can be pointed
out is establishment of regional centres of advisory panels, as there is
plausibility of conflict of opinion between the State Govt and Central Govt in
matters of cinema as such regional centres would be physically located in
different states and states might forward the argument of inclusion of theatre,
cinema and entertainment in Entry 33 of State List.
Another legal aspect to be taken into
consideration is the constitution of the Central Board of Film Certification
under Sec.3 of the Act. The Chairman and other appointees are under the
ultimate control of the Central Govt , again as mentioned in the aforementioned
case of advisory panels, their appointment, service conditions and other
allowances would be as prescribed , i.e., according to rules made by the
Central Govt on this behalf[10]. On
perusal of the above framework, it is clear that such hierarchical relationship
between the Central Govt and other regulatory bodies would hamper their work in
a manner free of fear or favour. Another key safeguard omitted from the
provisions, is the security of tenure of the Chairman and members of the CBFC,
implying that they continue in office at the pleasure of the Central Govt. This provides leeway to the Govt. to further
their vested interests and objectives in matters of certification of films.
Focusing on Sec.5B of the Act[11] , it lays
down principles for guidance pertaining to certification of films . The word
‘Principles for Guidance’ suggests that these are principles formulated for the
purpose of merely guiding the Board and not obliging it , again leaving a realm
for arbitrariness and abuse of power. The wordings are formulated precisely as
those found under Art.19(2) of the Constitution. Now, there are certain genres
of movies which are based on contentious issues . In those cases, sanction
would be refused to such films owing to restrictions which do not even strictly
fall within the ambit of Art.19(2). Also, a lack of explanation appended to the
said provision regarding restrictions , makes it cumbersome to arrive at a
clear -cut formula. Sec.5B(2) of the Act also empowers the Central Govt. to
issue directions in the nature of principles which ‘shall be complied’ by the
board , thus making it a requisite onus
on the Board to streamline their assignment in tune with the Government’s
satisfaction. Examining Sec.5 D of the Act[12],
the constitution of the Appellate Tribunal is also indirectly subject to the
powers of the Central Govt . The Chairman , mandated to be a retired HC Judge
or person qualified to be a HC Judge by the Act , is subservient to the
executive in terms of service conditions , appointment,etc. Where then, is the
independence and neutrality of the tribunal in disposing appeals ? Clearly,
lack of transparency and accountability in the functional aspects of statutory
and regulatory bodies , plagues the
entire legal framework[13].
Sec.5(E) of the Act provides for
suspension and revocation of certificates already granted in respect of films.
The grounds under which such an action might be taken are ambiguous. For Eg.,
what will be the nature and level of inquiry to be conducted to arrive at a
finding that the film was being exhibited in a manner which is inconsistent
with the grant of certificate ? It fails to provide for investigative or other
agencies which shall be competent to conduct such an inquiry . In case , there
is an alleged contravention, what shall be the appropriate procedure to search
the premises and what safeguards shall be available to the delinquent ? The Act
and the rules appended thereto fail to address these crucial questions. Also,
wide discretionary powers are conferred on the Central Govt, pertaining to
suspension & revocation of certificates granted, without clearly
stipulating certain , precise and unambiguous circumstances which shall attract
such punitive actions .
The term ‘satisfaction’ of the
Central govt is vague and debatable. Whether it is a personal satisfaction of a
few office bearers or a thorough detailed consultation with stakeholders? Such
unanswered questions , including the
question of justiciability of such satisfaction is a major stumbling block in
just and equitable implementation of the said provision. Failure to mention the
maximum period for which suspension of certificate shall be in operation,
arbitrarily empowers the Central Govt. to suspend it for an indefinite period
of time, thereby revoking the said certification in effect , which shall
deleteriously impact the free expression of thoughts , idea and creativity of
filmmakers. When the Censor Board has already scrutinised the film before its
exhibition and certification, subjecting such certified films to rigorous and
unguided scrutiny by the Central Govt. on frivolous grounds yet again, is
nothing short of a vicious circle ,undermining free expression and dissent.
Sec.5 F of the Act which empowers the
Central Govt., with power of review of its orders of suspension and revocation
, is flawed. If CBFC is the statutory authority for granting certification to
films according to the letter of the statute, why have powers of suspension ,
revocation and review been attributed to the Central Govt ? Such erroneous
division of power leads to inefficiency and duplicacy. Proponents argue that a safeguard is enunciated in the provision, in
the form of representation by the applicant or a person to whom rights have
been passed subsequently. But the nature , form and substance of representation
is not spelt out clearly in the provision , which renders it a mere formality.
Even if the Board has a divergent
opinion pertaining to the above mentioned matter, it is bound to act in
conformity with the Central Govt’s final order[14].
Revisional powers of the Central Govt
. stipulated under Sec. 6(1) wherein the Govt. has absolute powers to call for
record of proceedings from the Board or Tribunal ( in a case where the matter
has been finally decided ) , is a colourable exercise of power and a virtual
dilution of powers of the Board and Tribunal[15]. Exercise of revisional powers by the Central
Govt., over and above a final decision of the Tribunal is surpassing the
quasi-judicial functions of the Tribunal and hence against the doctrines of
separation of powers , basic structure of the Constitution , rule of law and
absolute usurpation of power and functions. Ultimately, this provision is a leeway
for the Central Govt. to exercise adjudicatory functions thereby jeopardising
the basic tenets of constitutionalism. The proviso sets forth that in
exercising revisional power , the Central Govt. is under no bounden duty to
disclose any fact which in its opinion is against the public interest to
disclose . It has certainly provided immunity to the Govt. to conceal facts
under the nomenclature of public interest. A due consideration of Sec.7F points
out to the bar of legal proceedings against the Central Govt, Board , Tribunal
or its members thereof , in respect of action taken in good faith . Again , how
will good faith be determined ? Clearly , there lies no remedy for the affected
filmmakers to seek restitution , reparation or compensation from the erring
authorities .The Act provides that the Central Govt. has the power to exempt
films or certain classes of films from operation of this Act and rules[16]. But what
shall guide it in granting such exemptions is not discussed and this might lead
to unreasonable classification and violative of Art 14.of the Constitution.
Finally, whimsical exercise of power
for the purpose of curtailing freedom of speech and expression through cinema
violates fundamental rights[17]. Such
capricious conduct also violates Art19.(1)(g) of the Constitution . Therefore
not only fundamental rights of film makers are infringed, but also citizens’
right to know is transgressed[18].
3.CONCLUSION
In this research paper , we undertook
an in-depth analysis of the cultural , economic, socio-political,
constitutional and legal aspects of cinematography . We analysed the ways in
which cinema plays a vital role in expressing creative and innovative ideas. It
is also a pivotal means to express dissent and divergent attitudes. The citizenry of a state have a right to know
and inform themselves on various issues concerning the state through media and
cinema. A truly democratic nation ensures promulgation of laws in consonance
with a value based approach which emboldens freedom of thought and expression
thereby adhering to underlying principles of constitutionalism.
Various loopholes in the
Cinematograph Act have bestowed the Central Govt. with ample discretionary
powers hindering transparency and accountability . The autonomy of regulatory
and recommendatory bodies under the Act have been compromised as a result of
loosely defined terms and usurpation of power by the executive in many
circumstances . For bolstering the due implementation of the Act , it is
imperative that a fine balance be struck between individual and collective
rights by laying down a detailed framework , as we have clearly seen numerous
lacunae under the current regime .
Although ethical questions pertaining
to cinematography manifesting in the form of morality , decency, defamation and
contempt of court are also significant and cannot be overlooked owing to
collective rights and public interest , but the very fact that there is in
place a system of classification for certification of films depending on the
content hosted by filmmakers and a licensing mechanism for the purpose of
regulating exhibition of films , acts as
a safety valve against misuse of freedoms provided under our Constitution.
Adequate penalties are also provided under the Act for those found in
contravention of the rules and regulations . Therefore , our civil society
should vehemently oppose any unjustified restraints on artistic expressions and
our Government should be guided by principles of reasonableness ,legitimacy and
proportionality in matters pertaining to film certification . Only then , India
will stand true to the construction, ‘Mother of all Democracies’.
3.1 SUGGESTIONS
Firstly , the rule- making power of
the Central Govt. should be directed towards notifying appropriate and
reasonable rules in order to address
gaps in the Cinematograph Act. Also, such rules should be subjected to
strict scrutiny by the Parliament , Judiciary and other stakeholders in order
to ensure that such rules do not transgress and circumvent fundamental rights.
Secondly, effort should be made towards making the Central Board of Film
Certification more representative in character as it would encompass numerous
perspectives relating to film certification and exhibition. Thirdly, in order
to develop CBFC as a resilient regulatory body, it is imperative that the
Chairman and members of the board be assured security of tenure and
predetermined service conditions according to law made by Parliament in this
behalf. Strengthening autonomy of the Board implies safeguarding freedom of speech
and expression . Therefore, it is noteworthy that salaries of members be paid
out of the Consolidated Fund of India in order to defend this right from being
compromised. Fourthly, an active cooperation is demanded between the Central
Govt. and State Govt in matters of film exhibition , preventive and mitigative
measures to impede any law and order exigency that might arise owing to release
of films in states,notwithstanding divergent ideologies and perspectives .
Finally, it is peremptory that our civil society maintain cohesiveness and
tolerance in order to reap paramount benefits from the freedom of press and
cinema.
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