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2026 Supreme(Online)(Mad) 32766

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Sushrut Arvind Dharmadhikari, CJ, G.Arul Murugan, J
Sheela Selvi.N – Appellant
Versus
The Chief Election Commissioner Election Commission of India (ECI) – Respondent
WP No. 14331 of 2026



Advocates:
For the Petitioner(s): Ms. Sheela selvi.N
For Respondent(s): Mr. Niranjan Rajagopalan Standing Counsel for R1 and R2

CBFC certification creates presumption of compliance; cannot be stalled by minority objections post-release.

Headnote:The petitioner sought a writ of mandamus directing election authorities to ensure free and fair elections under Article 324 and a ban on the film's screening under Articles 21 and 25 until elections conclude or geopolitical normalization, with censorship of derogatory content against neighboring countries. The film was certified by CBFC on 19th March 2026 without prior challenge, presuming consideration of public order guidelines. The Court found no basis to interfere post-certification. The key issue was whether CBFC certification could be overridden to ban the film due to alleged impacts on elections and rights. The Court relied on a prior identical rejection in a similar petition, holding that expert body clearance prevails over objections from a small section. Writ petition dismissed with no order as to costs.

Table of Content
1. petition seeks election conduct and film ban directions. (Para 1)
2. prior rejection applies; petition dismissed. (Para 3)

PRAYER : Petition filed underArticle 226of theConstitution of Indiaseeking issuance of a writ of mandamus to direct the first respondent and second respondent to hold free, fair and peaceful elections upholdingArticle 324of the which mandates the Commission to discharge of its constitutional responsibility of conducting free, fair and peaceful elections in the country as well as instruct the third and fourth respondents to issue/ensure a total ban against the screening of the said movie and not to permit the screening of the Movie Durandhar-2(The Revenge) in any form, including OTT Platform indefinitely, or till the Geopolitical situation becomes normal as well as until the Results of Lok sabha/General Elections 2026 all over India are declared; the said movie may be totally banned or screened only after censoring all derogatory statements against Pakistan and Bangladesh which were once a Part of our Great Indian Subcontinent (Hindustan) as well as censoring the scenes and dialogues which particularly grossly violate the fundamental rights of Indian citizens guaranteed under Articles 21 and 25 of theConstitution of India.

For Petitioner(s): Ms. Sheela selvi.N For Respondent(s):Mr. Niranjan Rajagopalan Standing Counsel for R1 and R2 ORDER (Order of the Court was made by the Hon'ble Chief Justice)

The petitioner has filed this writ petition, styled as public interest litigation, seeking issuance of a writ of mandamus to direct the first respondent and second respondent to hold free, fair and peaceful elections upholdingArticle 324of theConstitution of Indiawhich mandates the Commission to discharge of its constitutional responsibility of conducting free, fair and peaceful elections in the country as well as instruct the third and fourth respondents to issue/ensure a total ban against the screening of the said movie and not to permit the screening of the Movie Durandhar-2(The Revenge) in any form, including OTT Platform indefinitely, or till the Geopolitical situation becomes normal as well as until the Results of Lok sabha/General Elections 2026 all over India are declared. A further direction is sought to the effect that the said movie may be totally banned or screened only after censoring all derogatory statements against Pakistan and Bangladesh which were once a Part of our Great Indian Subcontinent (Hindustan) as well as censoring the scenes and dialogues which particularly grossly violate the fundamental rights of Indian citizens guaranteed under Articles 21 and 25 of the . 2. It is not in dispute that the film was released on 19thMarch, 2026. The petitioner, till date, has not chosen to challenge the CBFC certification issued to the film. Once the certificate has been issued, there is prima facie a presumption that the authority concerned has taken into account all the Guidelines, including public order.

3. A similar challenge made to the release of the same film was rejected by this Court vide order dated 10.4.2026 passed in W.P.No.14335 of 2026 , holding that once the expert body has considered the impact on the public and has cleared the film, merely because a small section of the society has a different view, the exhibition of the film cannot be stalled. The said reasoning applies on all fours to the case on hand.

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