On 3 July 2026, Honey Trehan’s long-delayed biopic Panjab ’95 appeared on the streaming platform Zee5 under a new title: Satluj. The film explores the life of Jaswant Singh Khalra, the Indian Sikh activist who exposed thousands of extrajudicial killings and forced cremations by the Punjab Police during the insurgency of the 1980s and 1990s.

The release marked the apparent end of a censorship battle that had lasted over three years. First submitted to the Central Board of Film Certification (CBFC) in 2022, Panjab ’95 was initially asked to make twenty-one cuts. But over time, the censor board reportedly demanded as many as a hundred and twenty-seven changes, including the removal of Khalra’s name, places, religious references, the Indian flag, and court-verified figures. Despite the filmmakers agreeing to dozens of these, the film remained unreleased, with the censor board deeming it “too contentious”.

Eventually, the filmmakers abandoned a theatrical release altogether. Unlike films released in Indian cinemas, streaming releases do not currently require CBFC certification and instead fall under the Information Technology Rules, 2021. The film could therefore appear on Zee5 in what Trehan described as its complete, original form—with only the title having changed.

The victory lasted two days.

On 5 July, Satluj disappeared from Zee5 in India. The platform announced that “in light of the current developments, Satluj will be unavailable in India until further notice”. Government sources subsequently said that the Centre had directed Zee5 to take down the film, citing security concerns and the Information Technology Rules, 2021. The film was later removed from Zee5 internationally as well.

Despite being commonly called the “censor board”, the CBFC is officially the Central Board of Film Certification, since 1983. It functions under the Ministry of Information and Broadcasting, responsible for certifying films for public theatrical exhibition across India.

The distinction between certification and censorship is important. A certification body should, in principle, classify films according to their suitability for different audiences rather than determine what those audiences are permitted to see. Yet the CBFC has continued to demand cuts and modifications before granting certificates or to refuse certification altogether.

Under the Cinematograph Act, the CBFC is led by a chairperson, with board members and advisory panels, all appointed by the central government. Films intended for theatrical exhibition are submitted to the Board for certification and classified according to age and audience suitability. The system is national, although state governments possess separate powers that can affect the public exhibition of films.

For Indian filmmakers and audiences, censorship has always been the norm. Most Indian filmmakers have their own unique stories of negotiating with the censor board over depictions of violence, profanity, sex, or political issues in their films. 

However, understanding why a body ostensibly designed to certify films has exercised such extensive power over their content requires going back to the origins of Indian cinema itself, and the long history of film censorship rooted in enduring colonial logic. While the specific institutions, laws and technologies involved have changed considerably over the years, the underlying question has proved far more durable: who should have the authority to decide what Indian audiences are allowed to watch, and what mechanisms the state has used to exercise this authority? 

The answer is a history of shifting rules, arbitrary decisions, court battles and filmmakers fighting back. It is also a history of how a system created under colonial rule survived independence, and how, time and again, attempts to make it more about certification than censorship fell short.

Colonial Origins: Censorship Arrives With Cinema

Released in 1913, the first feature film to be made in India was Raja Harishchandra, produced and directed by Dadasaheb Phalke. This marked the beginning of Indian cinema.

Just four years later, in 1917, a Bill was introduced in the Imperial Legislative Council, highlighting the need “to ensure proper control of cinematograph exhibitions” and “prevent the presentation to the public of improper or objectionable films”. It noted that “the rapid growth in the popularity of cinematograph and increasing number of such exhibitions in India have rendered these [existing] provisions inadequate for the protection of the public from indecent or otherwise objectionable representations”. The Bill thus marked the birth of film censorship in India.

It consequently provided for the first version of a censor board, “the constitution of an authority which will be required to pass all films intended for exhibition in this country and which will have power to refuse the necessary certificate in the case of any film.” In her seminal book Producing Bollywood, anthropologist Tejaswini Ganti explains that filmmaking “has been an object of state regulation in India since colonial times through censorship, taxation, allocation of raw materials, and control over exhibition through the licensing of theaters.”

This regulation, she adds, reflects a “hypodermic-needle” understanding of media effects and influence, a simplistic top-down causal view in which cinema (and audiovisual media in general) can directly influence behaviour and shape attitudes and subjectivities. At the heart of how the Indian censor board has operated since colonial times lies this conception of cinema: as not only directly influencing behaviour, but also extremely popular and widely consumed.

More fundamentally, this belies a patronising attitude towards Indian citizens: deemed unable to think for themselves and make informed decisions about the films they watch, they need the state to control, guide and dictate what is suitable. From the 1917 Bill came the Cinematograph Act of 1918, the first law governing film censorship in India. This Act conferred on the district magistrate the authority to give licences to film exhibitors. It also enabled the government to appoint inspectors to certify whether films were “suitable for public exhibition”.

But the criteria for “suitability” were only established in 1920, when censor boards were set up in certain towns across British India and run by their police chiefs. “No generally and rigidly applicable rules of censorship can be laid down,” began the general principles of the Bombay Board of Film Censors, before listing 43 objectionable subjects. These ranged from negative portrayals of the King and colonial officers to gruesome violence to immodest representations of female sexuality.

Yet, the main focus of the colonial government was on curbing expressions of nationalism, from any mention of colonial atrocities to the Indian National Congress to ideas of swarajya (self-rule). Any mention of M.K. Gandhi, in particular, was off limits. Colonial censorship was strict, and only got more insecure leading up to Indian independence in 1947. The censor boards across British India worked separately, each responding to unique local factors, something that would change under a unified, independent India.

Independence Without De-Censorship

Within the first few years of independence, the Central Board of Film Censors was established, with U (Universal) and A (Adult) as the certification categories. Film censorship was centralised in independent India, but with the same spirit as the colonial 1918 Act. It was just given a different legal framework: the Cinematograph Act of 1952, which film critic Uday Bhatia calls “the cornerstone—and, in many ways, the millstone—of film censorship in India.”

Like its colonial predecessor, the primary aims of this Act were to regulate the public exhibition of films in India by certifying them, to maintain public order, decency and morality, and to protect the sovereignty and integrity of India. Section 3 establishes the CBFC, its constitution, and powers: it would be led by the chairperson, under whom would be a board of members and subsequently advisory panels; all these individuals were to be appointed by the government. Section 4 mandated that films had to be certified before public screening.

Section 5 was arguably the censorship clause. Section 5A empowered the CBFC to grant or refuse a certificate, while Section 5B(1), borrowing from Article 19(2)—the reasonable restrictions on free speech—listed grounds for refusal or cuts: “A film shall not be certified for public exhibition if… the film or any part of it is against the interests of the sovereignty and integrity of India, the security of the State, friendly relations with foreign States, public order, decency or morality, or involves defamation or contempt of court…”

Here, the language was deliberately broad and vague, allowing for subjective interpretations by the CBFC, which was essentially set up to be an arm of the government.

Thus, while the Act claimed to be for the certification of films, it outlined a framework for decades of subsequent censorship, giving the Indian government considerable discretionary power along the lines of the colonial government.

A Constitutional Exception for Cinema

A notable example of these powers playing out came in 1968, when K.A. Abbas, a renowned author, journalist and filmmaker, made a short, documentary-style film, A Tale of Four Cities, which explored social and economic inequalities and included a brief scene depicting prostitution and poverty.

The film was granted an “A” certificate, which Abbas contested not only with a revising committee but also with the central government. He finally petitioned the Supreme Court, positing that this kind of “pre-censorship” violated Article 19(1)(a), freedom of speech and expression, arguing that films should not be subject to more stringent scrutiny than other forms of expression like newspapers or books. He demanded that the 1952 Cinematograph Act be declared unconstitutional.

The Supreme Court upheld the constitutionality of film censorship under the 1952 Cinematograph Act, noting that films “have a stronger impact”: they can “stir deeper emotions due to visuals and sound. Therefore, reasonable censorship is constitutionally valid.”

There were caveats: censorship must be guided by law with clear and fair procedures, and the categorisation of films should support differentiated audience suitability. A key quote from the judgment stated: “The censorship of films, their classification according to the age groups and their suitability for unrestricted exhibition with or without excisions is regarded as a valid exercise of power in the interest of public morality, decency, etc.”

At the time, Abbas was also part of a committee chaired by Justice G. D. Khosla to evaluate the Cinematograph Act of 1952 and its application, alongside R.K. Narayan, Umashankar Joshi, Romesh Thapar, Tara Sapre and four CBFC members. The committee’s main recommendation was to establish a truly autonomous censor board.

“Censorship should be exercised not by a department of the state whose decisions are subject to revision, appeal, or interference by the government,” the committee’s report, submitted 26 July 1969, stated, “but by an independent body which has been given sufficient authority and a sufficient sense of responsibility to deal with the matter finally and irrevocably.”

They also stressed that the existing binary categorisation as U and A was not nuanced enough. Instead, they suggested adding a third tier called G (General, meaning children only when accompanied by adults) that would sit between the two.

Finally, the committee report advocated liberal standards towards the representation of sex and nudity. “If… it is logical, relevant or necessary to depict a passionate kiss or a nude human figure,” they argued, “there should be no question of excluding the shot, provided the theme is handled with delicacy and feeling, aiming at aesthetic expression and avoiding all suggestion of prurience or lasciviousness.”

These recommendations were largely not implemented in law, although they fuelled debate for decades to follow. Many subsequent developments, judicial and extra-judicial, largely contradicted the vision of this committee.

When Emergency Powers Meet Cinema

The discretionary powers conferred by the 1952 Act were most brazenly abused to silence dissent during the Emergency, a 21-month period in which Prime Minister Indira Gandhi declared a state of internal emergency under Article 352 of the Indian Constitution. It was characterised by the suspension of civil liberties, mass arrests of opposition leaders, protesters and student leaders, and immense censorship.

In this context, Gulzar’s Aandhi was up for release in 1975. The film follows Aarti Devi, a rising female politician, and her estranged husband, who manages a hotel. Widely seen as mirroring Gandhi’s life, especially in the protagonist’s appearance, Aandhi was banned in mid-1975. The trigger for the ban was the distributors’ marketing of the movie with the tagline, “See your Prime Minister on screen,” which violated the Election Code of Conduct.

Gulzar subsequently re-shot certain scenes, adding one in which Aarti Devi calls Indira Gandhi her “ideal” to distance the character from the Prime Minister. Only after the Janata Party came to power in 1977 was the ban lifted, and Aandhi premiered on Doordarshan.

Another film, Amrit Nahata’s Kissa Kursi Ka, was a political satire on the Emergency. It included characters like Gangaram, which caricatured Indira Gandhi’s son Sanjay Gandhi, and Janta, a mute woman symbolising the voiceless, silent public amid rising authoritarianism. This explicit criticism of the ruling Congress Party and the Gandhi family led the I&B Ministry to confiscate the film prints until Nahata finally remade the film and released it in 1978 under the Janata government.

Additional films like I.S. Johar’s satire Nasbandi and Satyajit Ray’s documentary Sikkim also met with censorship, demonstrating how, under an authoritarian government, the CBFC and the wider powers of the state could easily be used for politically motivated censorship.

However, there is one notable exception from the time: Shyam Benegal’s Nishant (1975), about peasants revolting against oppressive landlords during the Telangana agitation of 1946–51. Highlighting issues of feudal injustice, inequality, oppression and resistance, the film was refused certification by the CBFC.

Despite being India’s official entry to the 1975 Cannes Film Festival, Nishant was essentially banned in India—quite like Satluj decades later. Yet in a curious turn of events, Indira Gandhi watched the film in a special screening.

“After the screening,” Benegal recalls, “the only comment the Prime Minister made was to ask why the film had been denied a censor certificate. She felt that denying a censor certificate… would make the government seem insensitive and petty.”

The CBFC reversed its decision and certified Nishant, allowing it to be released in India. Benegal recognised that such direct patronage from the Prime Minister saved his film and potentially his career from suppression. This example doesn’t vindicate the Indira Gandhi regime, but reiterates the arbitrariness of CBFC decisions and its lack of independence from the ruling party of the time.

The Long Fight to Turn Censorship Into Certification

The early 1980s saw considerable reform of the CBFC and film censorship laws in India. Most importantly, the Film Certification Appellate Tribunal (FCAT) was formally created in 1983 under Section 5D of the Cinematograph Act, 1952.

Helmed by a chairperson—a retired High Court judge or equivalent—along with four members, including a government-appointed secretary, the FCAT was a statutory appellate mechanism for filmmakers dissatisfied with CBFC decisions, like a refusal to certify, an Adult certification, or demanded cuts and modifications. Members sometimes included people from the film fraternity, making it more sympathetic to artistic concerns.

The FCAT thus served as a buffer between filmmakers and the CBFC, who would otherwise have to endure lengthy and expensive legal battles to contest its decisions. For filmmakers, it provided a faster, more efficient review process, which was also more sensitive to creative concerns.

Since its inception, the FCAT often overturned unreasonable or overly moralistic objections by the CBFC. A prominent example is the release of Bandit Queen (1994), wherein the FCAT famously overturned the CBFC’s demand for over 100 cuts. Specifically, the tribunal advised the censor board representative to “take a trip to Khajuraho to understand the difference between nakedness, nudity, and obscenity” and granted certification with minimal edits.

Another example is Lipstick Under My Burkha (2016), which the CBFC rejected for being “lady-oriented” with “audio pornography”. The FCAT intervened and ordered only a few minor cuts before granting an “A” certificate for the film's release. Even the political documentary An Insignificant Man was halted by the CBFC, which demanded No Objection Certificates from political stakeholders and muted the names of political parties. The FCAT rejected this and granted the documentary a U/A certification “without any cuts”, emphasising the centrality of free speech over concerns about reputation and public image.

During the same period as the FCAT was being set up, the government officially renamed the CBFC from the Central Board of Film Censors to the Central Board of Film Certification. This semantic change reflects the key role of the CBFC as a certification board for viewer guidance and age-based restrictions, rather than a censor board for suppressing cinema.

“This term [‘censor’] was coined when we were a British colony, and information had to be ‘censored’,” reflected two-term CBFC member Vani Tripathi Tikoo in 2017. “We need to be a certification body.” Yet this change of name seems to have been largely symbolic rather than substantive. In practice, the CBFC continued to function as a censoring body, using its discretionary power to selectively and arbitrarily censor films.

When the Mob Becomes a Censor

By the 1990s, however, censorship was no longer exercised only through the censor board. The decade saw what anthropologist William Mazzarella describes as an unprecedented “censor-wave”, emerging from the simultaneous rise of globalisation and the Hindu Right. Economic liberalisation brought an influx not only of goods but also of cultural products from the West, including greater access to Hollywood cinema and other popular culture. Almost simultaneously, the electoral rise of parties like the BJP and Shiv Sena brought a cultural and moral panic about the influx of Western values.

The Hindu Right recognised what media scholar Shohini Ghosh calls the “subversive potential of popular cinema”. In its 1998 electoral manifesto, the BJP stated that “a healthy polity [...] cannot survive without [...] an extra-political moral order”, in which “the media plays a very important role both in fostering and prejudicing such a moral order”. The party therefore committed itself to checking what it called the “abuse of popular cinema”.

The resulting censorship operated largely along two fault lines: sexuality and communal politics. Bandit Queen (1994), which portrayed the life of Phoolan Devi, a dacoit turned politician, was initially denied certification for its explicit depiction of sexual violence. The Supreme Court eventually cleared it, citing its “social value” and “historical relevance”.

But the more significant development of the decade was the growing power of forces outside the censor board. Violence and threats from Hindu nationalist groups could determine whether a film was actually shown, even after the CBFC had approved it. Deepa Mehta’s Fire (1996), about a lesbian relationship between two Indian women, demonstrated this new dynamic. The CBFC initially passed the film uncut. Yet Hindu nationalist groups attacked cinemas screening it, forcing theatres to stop showing the film. A movie that the official censor had permitted Indian audiences to watch was effectively censored by the threat of violence. Fire was subsequently sent back to the CBFC before being re-released without cuts.

Mani Ratnam’s Bombay (1995), which portrays a Hindu-Muslim marriage against the backdrop of the 1992–93 Bombay riots, similarly faced protests, bomb threats and lawsuits, alongside cuts from the CBFC and bans in several states.

Censorship was therefore becoming more diffuse. The censor board retained its considerable legal authority, but filmmakers, distributors and cinema owners increasingly had to anticipate another question: not simply whether the state would certify a film, but whether somebody might respond violently if it did. The threat itself could determine what reached the screen.

The Courts Push Back

The judiciary sometimes provided a counterweight to both forms of censorship. One of the most important precedents came in the S. Rangarajan v. P. Jagjivan Ram case of 1989, when the release of the Tamil film Ore Oru Gramathile, which criticised caste-based reservations, was halted over fears of political unrest.

The Supreme Court rejected the argument that the possibility of a hostile reaction justified suppressing the film. “Freedom cannot be suppressed on account of threat of demonstration and processions or threats of violence,” the judgment stated. The state, in other words, could not simply capitulate to those threatening violence and then use that threat as the justification for censorship.

There were other instances of courts upholding free expression against the CBFC and other state institutions. Documentary filmmaker Anand Patwardhan repeatedly fought such battles over films critical of Hindu nationalist politics. Raam ke Naam (In the Name of God), which documented the Ram Janmabhoomi movement that culminated in the 1992 demolition of the Babri Masjid, faced attempts to prevent its exhibition. Courts repeatedly sided with Patwardhan in disputes over censorship and broadcast. When the national broadcaster Doordarshan refused to telecast one of his certified films, the Supreme Court ultimately insisted that the broadcaster could not suppress it merely because its content was controversial.

These interventions mattered because they established limits, however imperfect, on the censorial power of both the state and those who threatened violence. Alongside the FCAT, the courts offered filmmakers an avenue to challenge arbitrary decisions. Yet, they could only correct individual decisions after disputes arose. The structure that produced those disputes remained largely intact.

The Reform That Never Came

That became particularly apparent after the BJP came to power in 2014. In 2015, the CBFC acquired a new chairperson: film producer Pahlaj Nihalani. Ahead of the 2014 general election, Nihalani had produced a campaign-style music video titled “Har Har Modi, Ghar Ghar Modi”. He made little effort to conceal his admiration for the Prime Minister. “I am a Modi bhakt [devotee],” he said in a later interview.

Under Nihalani, the CBFC became notorious for a series of authoritarian and overtly moralistic decisions. In 2015, it cut the kissing scenes in Spectre by 50%. The following year, it demanded 89 cuts from Udta Punjab, a gritty film about drug abuse in Punjab. Among the proposed changes were removing every mention of “Punjab” and deleting words such as “parliament”, “legislators” and “elections”. The Bombay High Court intervened, allowing the film to release with just one cut.

In 2017, the CBFC denied certification to Lipstick Under My Burkha because, in its own words, “the story is lady oriented … there are sexual scenes, abusive words, audio pornography and a bit sensitive touch [sic] about one particular section of society”. This time, the FCAT intervened, allowing the film to be released with an Adult certificate.

The absurdity of these decisions demonstrated how much still depended upon the political and moral disposition of those running the Board. But Udta Punjab and Lipstick Under My Burkha also demonstrated the importance of the institutional checks surrounding it: when the CBFC overreached, filmmakers could still turn to the courts or the FCAT.

The controversies prompted yet another attempt at reform. In January 2016, the Ministry of Information and Broadcasting appointed a committee chaired by filmmaker Shyam Benegal, with members including Kamal Haasan, Rakeysh Omprakash Mehra, Piyush Pandey, Goutam Ghose and Bhawana Somaaya.

Its central recommendation was strikingly familiar: the Central Board of Film Certification should actually behave like a certification body. Rather than imposing cuts and modifications, it should classify films according to more nuanced age categories and leave adults to decide what they wanted to watch. The committee also recommended structural changes, including 50 per cent female representation and more transparent selection processes.

The panel submitted its report in June 2016. Its substantive recommendations were never implemented. Nearly half a century after the Khosla Committee argued that film certification should be exercised by a genuinely independent body, another government-appointed committee had reached much the same conclusion. The terminology had changed from “censorship” to “certification”. The basic problem had not.

The distinction remains unresolved. The history of Indian film censorship is not simply a history of individual films being banned, mutilated or delayed. It is a history of an institution created by a colonial government to protect supposedly impressionable subjects from dangerous images, inherited by an independent democracy, and repeatedly contested by filmmakers, committees, tribunals and courts.

More than a century after the first censorship law was introduced, Satluj brings that history back to where this story began. The film spent years negotiating with a board officially tasked with certification over which names, images and historical facts Indian audiences could be permitted to see. When its filmmakers eventually circumvented the CBFC altogether by releasing the film on streaming, it disappeared anyway.

In one sense, there is nothing particularly new about this. From the colonial government’s attempts to suppress nationalist cinema to the censorship of the Emergency, the Indian state has long treated film as something too powerful—and its audiences as too impressionable—to be left alone. Governments have changed; the underlying architecture has proved remarkably durable.

What has changed is where censorship takes place. The censor is no longer confined to the censor board. The disappearance of Satluj from a streaming platform points to a much broader system of control involving not only certification but also governments, courts, corporations, police complaints, political organisations, online mobs and, increasingly, filmmakers themselves.