The Tribunal held that the impugned scenes and the use of vernacular slurs was permissible and added that вЂњto delete or to reduce these climactic visuals would be a sacrilege.вЂќ By a unanimous order of the Tribunal, an вЂњAвЂќ certificate was granted to the film without requiring deletion or modification of any scenes. The guidelines also obliged the Censor Board to ensure that вЂњhuman sensibilities are not offended by vulgarity, obscenity or depravityвЂќ and that вЂњscenes involving sexual violence against women like attempt to rape, rape or any form of molestation or scenes of a similar nature are avoidedвЂќ and should be kept to a minimum if absolutely necessary.ДЄs a result of the condition that certain scenes be deleted or amended, the order of the Censor Board was appealed to the Appellate Tribunal (the Tribunal). In addition, in 1991 the Indian Government had issued guidelines in terms of the Act which stipulated that film certification must ensure that вЂњartistic expression and creative freedom are not unduly curbedвЂќ and that вЂњcertification is responsive to social changeвЂќ. The Act stated that вЂњa film shall not be certified for public exhibition if, in the opinion of the authority competent to grant the certificate, the film or any part of it is against the interests of, inter alia, decencyвЂќ. In July 1995, the Censor Board indicated that it would grant the film an вЂњAвЂќ certificate (films considered suitable for exhibition restricted to adults only) in terms of the Cinematograph Act, 1952 (the Act) but only on the condition that certain scenes were deleted or modified. The film contained explicit scenes of rape and nudity.

The film was based on the book about the incident written by Mala Sen. In 1994, Bobby Art International, a film production company, made a film titled вЂњBandit QueenвЂќ which was based on a true story about a village girl who was raped and brutalized, and who subsequently became a member of a violent criminal gang as a means of revenging herself upon society. This analysis was originally prepared by ARTICLE 19

The Court held that the scenes featuring nudity and expletives served the purpose of telling the important story and that the producersвЂ™ right to freedom of expression could not be restricted simply because of the content of the scenes. The producers of the film, which told the true story of a woman who was raped and brutalized before taking revenge on her attackers, had approached the Court seeking the reinstatement of the classification of the film as вЂњAdult onlyвЂќ. The Supreme Court of India set aside the decision of the Delhi High Court which had restrained the screening of the movie вЂњBandit Queen, holding that the screening of a film cannot be prohibited merely because it depicts obscene and graphic events.

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