Overview
The Madras High Court on 10 April 2026 dismissed two writ petitions that sought to prohibit the screening of the film “Dhurandhar 2: The Revenge” in Tamil Nadu until the conclusion of the state assembly elections. The petitioners argued that the movie violated the Model Code of Conduct and that it amounted to electioneering by the ruling party.
Key Developments
- The bench comprising Chief Justice S.A. Dharmadhikari and Justice G. Arul Murugan held that no law bars a film’s exhibition while the MCC is in force.
- The court observed that the petitioners had not challenged the certificate granted by the CBFC, and therefore it could not issue any restraining order.
- The petitioners cited Clause 4 of Chapter VII of the MCC, which prohibits the use of public funds and official mass media for partisan promotion, alleging that the film glorified the achievements of the BJP in areas such as counter‑terrorism and anti‑money‑laundering.
- A separate counsel claimed the movie incited communal tension and war‑like sentiment, but the court found no legal basis to act without a CBFC challenge.
- The court dismissed the petitions and ordered a detailed judgment to be delivered later.
Important Facts
• Case title: D Rakesh v. Chief Election Commissioner & Others.
• Citation: 2026 LiveLaw (Mad) 156.
• Writ Petition No.: WP 14335 of 2026.
• Petitioners: unnamed individuals and counsel representing concerns over election fairness.
• Respondents: film’s producers Adithya Dhar, Lokesh Dhar and producer Jyoti Deshpande.
Exam Relevance
The judgment underscores the constitutional balance between freedom of expression and electoral integrity, a frequent topic in GS2: Polity. It illustrates how the Model Code of Conduct operates in practice, and why challenges must be directed at the statutory certifying body (CBFC) rather than the content itself. Aspirants should note the procedural requirement of challenging a CBFC certificate to invoke judicial intervention, reflecting the doctrine of separation of powers.
Way Forward
Future litigants seeking to curb media content during elections should first approach the CBFC for revocation or modification of the certificate. Additionally, the Election Commission may consider issuing specific guidelines on political messaging in entertainment media to pre‑empt similar disputes. Monitoring of election‑related content will likely intensify, making it essential for policymakers and legal practitioners to balance artistic freedom with the sanctity of the electoral process.