Delhi High Court Allows Theatrical Release Of '120 Bahadur' Film As Producer Says Names Of All Soldiers Mentioned In Credits

The Delhi High Court on Wednesday allowed the pan India theatrical release of Farhan Akhtar starrer movie “120 Bahadur” based on the Battle of Rezang La in 1962.

A division bench comprising Justice Prathiba M Singh and Justice Shail Jain noted the submission of the film producer that names of all the 120 soldiers who fought the battle have been included as credits in the film.

The movie portrays Major Shaitan Singh Bhati, who was conferred the Param Vir Chakra for his bravery in the Battle of Rezang La in 1962. The film is slated for a theatrical release on November 21.

The Court disposed of a PIL filed by a charitable trust- Sanyukt Ahir Regiment Morcha, its trustee as well as other individuals claiming to be family members of the martyrs of the Battle of Rezang La. 

The plea challenged the CBFC certification granted to the film over allegations of distortion of historical facts. It further sought that the name of the movie be changed from “120 Bahadur” to “120 Vir Ahir”, to make “factual correction and inclusion of all 120 soldiers' names, and insertion of an appropriate disclaimer.”

During the hearing today, the petitioners' counsel said that while he was not pressing the relief for name change of the film at this stage, the names of all the 120 soldiers be added in the film.

The producer's counsel said that all the 120 names are already being mentioned in the end of the film as a tribute by way of an illustration.

The Court thus refused to pass the direction for name change of the movie at this stage, noting that the film is set to be scheduled for November 21.

It further directed the petitioner organization to watch the film and see if names of all the 120 soldiers are featured in the movie.

If any correction or editing is required, the producers have been directed to carry out the same in OTT release.

It is made clear that even for OTT, only the names of the soldiers, along with the proper regiment, etc, would be mentioned, the Court said.

The plea alleged that the movie distorts historical truth by singularly glorifying Major Shaitan Singh, as a lone protagonist under the fictionalised name “Bhati,” and erases the collective identity and community contribution of the Ahir soldiers who fought the battle.

It was averred that the impugned portrayal violates Section 5B(1)–(2) of the Cinematograph Act, 1952, and Guideline 2(xvii) of the 1991 Certification Guidelines, which prohibit the exhibition of films presenting a “distorted view of history.” It also contravenes Section 356 of the Bharatiya Nyaya Sanhita, 2023, which criminalises imputations against deceased persons wounding the sentiments of their relatives, the plea added.

Title: Sanyukt Ahir Regiment Morcha & Ors v. Union of India & Ors

Citation: 2025 LiveLaw (Del) 1539

Counsel for Petitioner: Mr. Gautam Jha, Ms. Harsh Lata, Advocates

Appearance for Respondent No. 4 – Excel Entertainment: Adv. Jay Kumar Bhardwaj, Adv. Priya Darshini Arora, Adv. Tanya Singh, Adv. Pranjal Patel