Telangana High Court Asks CBFC To Reconsider 'Girlfriend' Movie's U/A Certification, Says Nature Of Scenes May Impact Underage Viewers
The Telangana High Court has held that Telugu feature film starring actress Rashmika Mandana 'The Girlfriend' ought to have been granted an 'A' certificate instead of a 'UA 13+' certificate, after taking note of the film's portrayal of conduct inside a girls' hostel and its overall likely impact upon viewers below 18 years of age.
The Court said that it was not inclined to interfere with the content of the film, it however directed the Central Board of Film Certification (CBFC) to reconsider the film's certification within four weeks.
Justice Nagesh Bheemapaka observed:
"Petitioner has specifically pointed out that the film depicts repeated entry of the male protagonist into the girls' hostel during night hours, portrays institutional acceptance of such conduct through the dialogue attributed to the caretaker/HOD that acts between consenting adults cannot be questioned, depicts concealment of incidents occurring inside the ladies' hostel by the female lead, and includes a scene showing the lead actor changing his pants in the corridor of the ladies' hostel in the presence of other occupants.These are not isolated objections to individual scenes but constitute the cumulative basis on which petitioner contends that the overall theme of the film is unsuitable for adolescent viewers.
This Court is conscious of the fact that cinema is a medium of artistic expression and that differing moral or social perceptions cannot ordinarily constitute grounds for judicial interference. At the same time, age-based classification under the Cinematograph Act, 1952 necessarily requires an assessment whether the overall impact of the film is appropriate for viewers falling within a particular age group. The distinction between "UA" Certificate and "A" Certificate is intended precisely to address such concerns...On an overall consideration of the pleadings, the objections specifically raised by petitioner regarding nature of scenes, dialogues, portrayal of conduct inside a girls' hostel and their likely impact upon viewers below the age of eighteen years, this Court is of the considered view that the film ought to have been classified under the category of 'A' Certificate rather than 'UA 13+' Certificate".
The court said that while it is not inclined to interfere with the artistic content of the film, it however found merit in the grievance relating to the category of certification.
"This Court therefore, holds that the Telugu feature film 'The Girl Friend' ought to have been granted 'A' Certificate instead of 'UA 13+' Certificate granted vide CC No. DIL/6/66/2025-HYD dated 03.11.2025 and Censor Certificate No. DIL/6/66/2025-HYD dated 03.11.2025," it said while directed the CBFC to "reconsider certification" and take a decision as per the Cinematograph Act, 1952, the Cinematograph (Certification) Rules, 1983 and the Guidelines issued under Section 5B(2) of the Act within 4 weeks.
The Court further held that although certification of films falls within the statutory domain of the CBFC, compliance with the certification procedure does not preclude judicial review where the grievance concerns the correctness of the category of certification.
"Certification is not merely a procedural exercise but involves balancing freedom of artistic expression with the legitimate interest of protecting children and adolescents from age-inappropriate content," it said.
The writ petition was filed by Arokya Swamy Joseph, who described himself as a social worker concerned with preserving moral values in society. He sought a direction to the CBFC to review the certification granted to the Telugu film The Girlfriend and replace its 'UA 13+' certificate with an 'A' certificate.
According to the petitioner, the film depicts the male protagonist entering a girls' hostel every night and portrays the hostel caretaker justifying the conduct on the ground that it involved two consenting adults. The petitioner contended that such scenes, along with the portrayal of the female lead concealing incidents occurring inside the hostel and another scene showing the hero changing his pants in the corridor of the girls' hostel in the presence of other occupants, conveyed inappropriate messages to adolescent viewers. He further argued that such depictions could discourage parents from allowing their daughters to pursue higher education while residing in hostels.
The CBFC opposed the petition, submitting that the film had been examined by an Examining Committee consisting of an Examining Officer and four Advisory Panel Members in accordance with the Cinematograph Act, 1952, the Cinematograph (Certification) Rules, 1983 and the Guidelines issued under Section 5B(2) of the Act. It stated that the committee unanimously recommended grant of a 'UA 13+' certificate, subject to excisions and modifications, and that the filmmakers had incorporated an appropriate disclaimer regarding cinematic liberties. It also contended that the Cinematograph Act contained no provision enabling the Board to review a certification once granted.
The film's distributor separately questioned the maintainability of the writ petition, contending that the petitioner lacked locus standi and that certification decisions could not be challenged through a public interest litigation. It also submitted that it had no role in the certification process, which lay exclusively within the statutory functions of the CBFC.
The High Court observed that the statutory procedure prescribed under the Cinematograph Act had been followed by the CBFC. However, it held that procedural compliance alone did not bar judicial scrutiny where the challenge related to the appropriateness of the certification category.
The Court noted that they were not confined to isolated scenes but related to the cumulative impact of the film on viewers below eighteen years of age. While recognising cinema as a medium of artistic expression, it observed that the distinction between a 'UA' certificate and an 'A' certificate exists precisely to ensure that films containing age-inappropriate content are suitably classified.
Rejecting the objection regarding locus standi, the Court held that the challenge was directed against the exercise of a statutory power by the CBFC and therefore could not be rejected merely because the petitioner was neither the producer nor the director of the film. It accepted, however, that the distributor had no role in the certification process.
Accordingly, the Court disposed of the writ petition and directed the CBFC to reconsider the certification.
Case Title: Arokya Swamy Joseph v. Government of India & Ors.
Case No.: W.P. No. 37102 of 2025