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2026 Supreme(Mad) 671

IN THE HIGH COURT OF JUDICATURE AT MADRAS
P.T.ASHA, J.
M/s. KVN Productions LLP, Represented by is Authorized Signatory, Mr. Venkata Narayana Konanki - Petitioner
Versus
Central Board of Film Certification, Films Division Complex – Respondent
W.P.No.380 of 2026 and W.M.P.No.445 of 2026
Decided On : 09-01-2026

Advocates Appeared:
For the Petitioner: Mr. Satish Parasaran, Senior Counsel for Mr. Vijayan Subramanian.
For the Respondent: Mr. A.R. L. Sundaresan, ASGI assisted by Mr. A.R. Sakthivel, Senior Panel Counsel.

The authority to refer a film to a Revising Committee exists only before a certification decision is made; post-approval actions are without jurisdiction.

Headnote:(A) Cinematograph Act, 1952 - Rules 22, 23, 24, 25, 26, 27, and 37 - Certification for film 'Jana Nayagan' under UA 16+ category - Petitioner sought Mandamus for grant of Censor Certificate after complying with prior requirements - Competent authority's decision to refer the film to Revising Committee post-approval by Examining Committee deemed without jurisdiction as it contravenes statutory procedures - Court rules that since proper procedures were followed for certification as per Rule 27, the prior decision stands firm and the certification must be issued immediately. (Paras 2, 6, 21, 28)

(B) Jurisdiction - Power of the Chairperson under the Cinematograph Rules to refer a film to the Revising Committee exists prior to final certification and cannot be exercised post-decision acceptance. (Paras 17, 21)

(C) Procedural Compliance - Importance of adhering to statutory requirements and significance of Examining Committee’s recommendations in the certification process. (Paras 13, 17, 18)

Table of Content
1. factual background of film certification process (Para 4 , 5 , 6 , 7 , 8)
2. petitioner and respondent's arguments on powers and procedures (Para 10 , 11)
3. court's examination of procedural lapses and complaints (Para 12 , 16 , 18 , 20)
4. court's analysis on jurisdiction of the chairperson (Para 21 , 22)
5. final order to grant certification based on compliance (Para 28)

ORDER :

P.T.ASHA, J.

The above writ petition has been filed for the following relief:

“To issue a Writ of Mandamus directing the respondents to grant Censor Certificate in the name of the petitioner being the producer of the film “Jana Nayagan” under UA 16+ category, as per the 2nd respondent communication dated 24.12.2025 within a period of 24 hours.”

2. On hearing the arguments on either side, the issue that engages the attention of this Court is as follows :

“Whether the competent authority, having already taken a decision of accepting the recommendation of the Examining Committee, has the right to revise its earlier decision?”

3. In order to appreciate the above issue, it is necessary to briefly set out the facts which has culminated in the filing of the above writ petition.

Since the entire arguments are based on the Cinematograph (Certification) Rules, 2024, oral submissions has been made by the learned senior counsel appearing on behalf of the petitioner and the learned Additional Solicitor General (ASG in short) who has also made elaborate submissions on the basis of the contents of the affidavit as well as the arguments advanced by the learned senior counsel appearing on behalf of the writ petitioner and the provisions contained in the Rules.

Facts of the case:

4. The petitioner is engaged in the business of production and distribution of cinematographic films, in the course of its business, has also produced the film “Jana Nayagan” which is the subject matter of this writ petition.

5. The lead cast actor for the above film are actors, Vijay, Prakash Raj and other leading artists from the South Indian Film Industry. The pre-production work for the above film started in May 2024 and the pooja ceremony for the said film was held on 04.10.2024. Thereafter on 05.10.2024, the principal shooting had commenced. On 15.12.2025, the post production work was completed and on 27.12.2025, the audio launch had taken place.

6. In the interregnum, on 18.12.2025, the petitioner had filed necessary application for censor certification. The same was acknowledged by the 2nd respondent's office on 19.12.2025 bearing No.01031912202500014. The said application had been submitted after complying with all the statutory requirements including payment of fees and submission of documents as contemplated under Cinematograph Certification Rules, 2024 , hereinafter referred to as “The Rules”. The petitioner thereafter received a communication from the 2nd respondent dated 22.12.2025 in which it was stated that after considering the written and oral submissions of the petitioner's authorized representative during the personal hearing and viewing of the film, the Examining Committee had recommended the grant of certification of the film under the category UA 16+ subject to the compliance of certain excisions and/or modifications.

7. On the basis of these communications, the petitioner submits that they had carried out all the excisions (as the Examining Committee had only recommended excisions) as directed by the 2nd respondent and resubmitted the revised version on 24.12.2025. The suggested cuts were expressly marked for re-submission. The 2nd respondent had, by communication dated 29.12.2025, informed the petitioner that the modifications had been verified and the petitioner would be granted 'UA 16+' certification. In the light of the above communication, the petitioner attempted to proceed with the final stage of certification process. At this juncture, they had encountered a technical limitation in the CBFC on-line portal as there was no provision to upload the audio descrip

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