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Madras High Court Rejects Petition to Ban ‘Dhurandhar 2’ Screening During Tamil Nadu Assembly Elections | GS2 UPSC Current Affairs April 2026
Madras High Court Rejects Petition to Ban ‘Dhurandhar 2’ Screening During Tamil Nadu Assembly Elections
The Madras High Court on 10 April 2026 dismissed petitions seeking to ban the film “Dhurandhar 2” in Tamil Nadu until the end of state assembly elections, holding that no law prohibits movie screenings under the Model Code of Conduct and that the CBFC certificate was unchallenged. The decision highlights the procedural limits of election‑related litigation and the role of statutory bodies like the CBFC and the Election Commission in safeguarding electoral fairness.
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 . UPSC 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.
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Overview

gs.gs258% UPSC Relevance

Court upholds artistic freedom, limiting Model Code’s reach over film screenings during elections

Key Facts

  1. 10 April 2026 – Madras High Court dismissed petitions seeking to ban "Dhurandhar 2" in Tamil Nadu.
  2. Petition details: D Rakesh v. Chief Election Commissioner, WP 14335 of 2026, citation 2026 LiveLaw (Mad) 156.
  3. Bench: Chief Justice S.A. Dharmadhikari and Justice G. Arul Murugan.
  4. Court held that no law bars a film’s exhibition while the Model Code of Conduct (MCC) is in force.
  5. Petitioners relied on Clause 4, Chapter VII of the MCC (prohibits use of public funds/official media for partisan promotion).
  6. The court noted that the petition did not challenge the CBFC certificate; therefore no restraining order could be issued.
  7. Outcome: Petitions dismissed; detailed judgment to be delivered later.

Background & Context

The case highlights the tension between the fundamental right to freedom of expression and the need to preserve electoral integrity under the Model Code of Conduct. It underscores the procedural prerequisite of approaching the Central Board of Film Certification (CBFC) before seeking judicial intervention, reflecting the doctrine of separation of powers.

UPSC Syllabus Connections

GS2•Representation of People's ActGS4•Information sharing, transparency, RTI, codes of ethics and conductEssay•International Relations and GeopoliticsGS1•Social Empowerment, Communalism, Regionalism and Secularism

Mains Answer Angle

GS‑2 (Polity) – Discuss the balance between freedom of speech and electoral fairness, analysing judicial pronouncements and the role of statutory bodies like the CBFC and Election Commission.

Full Article

<h3>Overview</h3> <p>The <span class="key-term" data-definition="Madras High Court — the highest judicial authority in the state of Tamil Nadu, exercising appellate jurisdiction and constitutional powers (GS2: Polity)">Madras High Court</span> on 10&nbsp;April&nbsp;2026 dismissed two writ petitions that sought to prohibit the screening of the film “Dhurandhar&nbsp;2: The Revenge” in Tamil&nbsp;Nadu until the conclusion of the state assembly elections. The petitioners argued that the movie violated the <span class="key-term" data-definition="Model Code of Conduct (MCC) — a set of guidelines issued by the Election Commission of India to ensure a level playing field during elections; it restricts the use of official resources for partisan purposes (GS2: Polity)">Model Code of Conduct</span> and that it amounted to electioneering by the ruling party.</p> <h3>Key Developments</h3> <ul> <li>The bench comprising <strong>Chief Justice S.A. Dharmadhikari</strong> and <strong>Justice G. Arul Murugan</strong> held that no law bars a film’s exhibition while the MCC is in force.</li> <li>The court observed that the petitioners had not challenged the certificate granted by the <span class="key-term" data-definition="Central Board of Film Certification (CBFC) — the statutory body that certifies films for public exhibition in India; its certification is a prerequisite for legal screening (GS2: Polity)">CBFC</span>, and therefore it could not issue any restraining order.</li> <li>The petitioners cited Clause&nbsp;4 of Chapter&nbsp;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 <span class="key-term" data-definition="Bharatiya Janata Party (BJP) — the ruling national party of India, whose policies and performance often become election issues (GS2: Polity)">BJP</span> in areas such as counter‑terrorism and anti‑money‑laundering.</li> <li>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.</li> <li>The court dismissed the petitions and ordered a detailed judgment to be delivered later.</li> </ul> <h3>Important Facts</h3> <p>• Case title: <strong>D&nbsp;Rakesh v. Chief Election Commissioner & Others</strong>.<br> • Citation: <strong>2026 LiveLaw (Mad) 156</strong>.<br> • Writ Petition No.: <strong>WP&nbsp;14335 of 2026</strong>.<br> • Petitioners: unnamed individuals and counsel representing concerns over election fairness.<br> • Respondents: film’s producers <strong>Adithya Dhar, Lokesh Dhar</strong> and producer <strong>Jyoti Deshpande</strong>.</p> <h3>UPSC Relevance</h3> <p>The judgment underscores the constitutional balance between freedom of expression and electoral integrity, a frequent topic in <span class="key-term" data-definition="GS2: Polity — the paper covering Indian polity, governance, and constitutional law (relevant for questions on courts, election law, and fundamental rights)">GS2: Polity</span>. It illustrates how the <span class="key-term" data-definition="Election Commission of India (ECI) — the autonomous constitutional authority that administers elections and enforces the Model Code of Conduct (GS2: Polity)">Model Code of Conduct</span> 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.</p> <h3>Way Forward</h3> <p>Future litigants seeking to curb media content during elections should first approach the <span class="key-term" data-definition="CBFC — as defined above, the body whose certification determines a film’s legality (GS2: Polity)">CBFC</span> 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.</p>
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Analysis

Practice Questions

GS2
Easy
Prelims MCQ

Model Code of Conduct – Election Law

1 marks
5 keywords
GS2
Medium
Mains Short Answer

Role of CBFC & Judicial Review

5 marks
5 keywords
GS2
Hard
Mains Essay

Freedom of Speech, Election Law, Media Regulation

20 marks
8 keywords
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Key Insight

Court upholds artistic freedom, limiting Model Code’s reach over film screenings during elections

Key Facts

  1. 10 April 2026 – Madras High Court dismissed petitions seeking to ban "Dhurandhar 2" in Tamil Nadu.
  2. Petition details: D Rakesh v. Chief Election Commissioner, WP 14335 of 2026, citation 2026 LiveLaw (Mad) 156.
  3. Bench: Chief Justice S.A. Dharmadhikari and Justice G. Arul Murugan.
  4. Court held that no law bars a film’s exhibition while the Model Code of Conduct (MCC) is in force.
  5. Petitioners relied on Clause 4, Chapter VII of the MCC (prohibits use of public funds/official media for partisan promotion).
  6. The court noted that the petition did not challenge the CBFC certificate; therefore no restraining order could be issued.
  7. Outcome: Petitions dismissed; detailed judgment to be delivered later.

Background

The case highlights the tension between the fundamental right to freedom of expression and the need to preserve electoral integrity under the Model Code of Conduct. It underscores the procedural prerequisite of approaching the Central Board of Film Certification (CBFC) before seeking judicial intervention, reflecting the doctrine of separation of powers.

UPSC Syllabus

  • GS2 — Representation of People's Act
  • GS4 — Information sharing, transparency, RTI, codes of ethics and conduct
  • Essay — International Relations and Geopolitics
  • GS1 — Social Empowerment, Communalism, Regionalism and Secularism

Mains Angle

GS‑2 (Polity) – Discuss the balance between freedom of speech and electoral fairness, analysing judicial pronouncements and the role of statutory bodies like the CBFC and Election Commission.

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