Bombay HC issues notice to CBFC over objection to film title ‘Janki’ and character names

The Bombay High Court on Monday asked the Central Board of Film Certification (CBFC) to reply to a petition filed by the makers of the Chhattisgarh-based film Janki. The CBFC has raised objections to the film’s title as well as the names of its lead characters.

According to the filmmakers, the CBFC objected to the title Janki because it refers to Goddess Sita. The Board also flagged the male character’s name, Raghuram. The film tells the story of Janki and Raghuram and their relationship set against an action-packed background. A bench of Justices Revati Mohite-Dere and Sandesh Patil directed the CBFC to respond to the petition by October 6.

The film features Dilesh Sahu and Anukriti Chouhan in lead roles and is directed by Kaushal Upadhyay. Initially made in Chhattisgarhi, it was later adapted into Hindi. The Hindi trailer, released with CBFC approval on May 16, 2025, was followed by an application for certification. On June 10, 2025, the CBFC informed the producers that the film had been screened, and the Examining Committee recommended a “UA 16+” certificate along with certain cuts and changes.

Among the changes suggested, the CBFC asked the producers to alter the film’s title and the names of the two main characters. The Board cited its guidelines aimed at avoiding hurt to religious or social sentiments. The filmmakers, however, argued that these directions infringe on their right to free speech and expression.

“The objections raised by the CBFC in its notices dated June 10, 2025 and July 15, 2025 are arbitrary, unreasonable, and unsustainable in law. The directions for excisions and modifications as contained therein are devoid of cogent reasoning and lack any statutory foundation under the Cinematograph Act, 1952 or the Rules framed thereunder. The CBFC have failed to apply its mind to the context and content of the scenes objected to, and have instead relied upon generalised and baseless assumptions. The impugned objections, being without justification, amount an infringement of the Petitioner's right to freedom of speech and expression guaranteed under Article 19(1)(a) of the Constitution of India,” the plea states.

The petitioners further argued that the names and title cannot be changed now as they have already been approved, registered, and widely publicised. They also pointed out that the CBFC has not given them a proper response despite their stand.

"Unless the impugned objections are quashed and set aside, we will suffer grave and irreparable prejudice, including loss of the scheduled release window, disruption of distribution arrangements, impairment of reputation and goodwill, and an adverse impact on his artistic freedom, none of which can be adequately compensated in monetary terms. The directions of the CBFC requiring alteration of the very title of the film and raising objections which are arbitrary, baseless, and devoid of statutory foundation, cannot be sustained in law. Compliance with such unjustified objections would not only cause severe financial loss to the Petitioner but would also undermine his creative work and destroy the substantial investment already made in the publicity and promotion of the film," the plea reads.

The filmmakers also cited a recent Kerala High Court judgment in M/s Cosmos Entertainments v. Regional Officer, CBFC (Janaki vs State of Kerala Film), which held that forcing a filmmaker to remove or alter the word Janaki from the title or dialogues amounts to an unconstitutional violation of the right to free speech under Article 19(1)(a).
(With Live Law Inputs)