Glorification of Harassment in Bollywood Movies: Can the Censor Board Undo It?

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‘Tera Naam’, ‘Toilet: Ek Prem Katha’, ‘Ranjhana’ are a few examples of glorification of harassment in Bollywood movies. Typically, in all these movies, a woman is chased by a man till she finally agrees and settles for him. Most of these movies and their perspectives are marked by a patriarchal mindset and masculine lens, often romanticising the victim’s trauma as an act of ‘falling in love’. However, these films, often blockbusters, do not account for how they affect the general populace. Tejaswi Shetty studies such performances of stalking and harassment potent in contributing to crime against women. She also understands the role of the Central Board of Film Certification (CBFC) and how they could be effective.

harassment in bollywood movies

By Tejaswi D Shetty,  a second-year law student at Sri Dharmasthala Manjunatheshwara Law College, Mangalore, Karnataka. 


The cultivation theory advanced by George Gerbner in the 1960s suggests that television’s threat resides in its power to mould people’s moral values and general perceptions about the world and not just a specific point of view and specific topic.[1]

The aspects of literature, music, art and cinema have always played a role in shaping society. Indian cinema, over time, has manifested violence and abuse as a symbolism of romantic relations between the characters. The representation of stalking and harassment is dramatised, making reality more feasible.

However, the fundamental right of freedom of speech and expression in Article 19(1)(a) does not offer absolute freedom. The judiciary has often intervened when a film offers obscenity, immorality, or an attack on the sentiments of communities of people. Further, the Central Board of Film Certification (CBFC) can censor motion pictures as per the instructions of the Cinematograph Act, 1952.  In addition to the particular restrictions outlined in section 5(B) of the Act on the grounds of reasonable restriction, the CBFC can ask the applicant to evaluate and change the objected part(s) of the motion picture that violates section 5(B) of the Act.[2]

The unharmed harassment in Bollywood movies, especially mainstream movies, has had disturbing repercussions in reality. Harassment in Bollywood and Indian cinema, in general, is often romanticised, but it has the potential to translate into brazen and malicious criminal acts.

In India, between a film that promotes stalking or harassment and another that harms the community’s sentiments, the latter is more likely to get banned.

The CBFC’s often look past such glorification of stalking and stalkers. However, the same needs to be questioned because it violates the Cinematograph Act (1952) provision, tainting the general audience with patriarchal and misogynistic values.

This paper will use a content analysis approach to examine the many components of mainstream Bollywood movies that promote stalking and harassment. It will start with a literature review of research on the same issue that has predated this piece and inspired it.

This paper has made assumptions based on a small survey to understand how mainstream Bollywood movies affect crime against women and harassment. At last, this piece will address whether or not the function of censorship is inadequate, and they are, in some ways, attempting to encourage such glorification.

The study conducted through this paper employs a selection of films to further assess the status of Indian cinema in terms of societal growth. A series of sampled movies in this study helps understand the scope of Indian cinema’s status quo in terms of social development. The trend of showing a purely distorted scene, in reality, is frequently seen in Indian cinema, and the CBFC also permits it. Thus, this study poses issues on the CBFC’s functioning.

Read how Bollywood movies valorise custodial death in India here.

Literature Review

The following research papers have been instrumental in understanding harassment in Bollywood and Indian Cinema, in general.

Samandha Smith, in the article ‘Prioritizing Stalking as Popular Culture in Regional Films – A Threat to Woman Status in Resurgent India’, uses the content analysis approach to discuss the role of characters in two films of actor Dhanush.

Movie 1 is a Bollywood movie, and the other is a Kollywood movie. It differentiated the movies regionally but narrowed them down to the same actor. The author has addressed the toxicity of harassment in Bollywood movies and kollywood, often soaked in heroism. The article also analyses how these movies deride women’s status in films. This research paper takes inspiration to use the same approach to understand the standpoint of Indian cinema.

In another article, ‘A Critical Overview of Censorship in Indian Cinema’, Satyam Rathore, includes the Censor Board’s function in the certification of films as specified by the legislation. The author also discusses how censorship has been misapplied in this case to limit freedom of speech via movies. But the author does not specify the lack of role played by the CBFC in outlawing representations of minimal crime, which in reality could cause serious consequences. Instead, the author cites numerous Indian case laws to describe the reason for establishing censorship boards.

In the article ‘India: Glorification of Stalking in Bollywood’ by Poulami Goswami, she includes various cases which show the consequences of promoting stalking as a kind of silly chase. The author has also mentioned recommendations and legal aspects which could be instrumental in changing how filmmakers project such scenes and how the courts could censor them.

Glorification of Harassment in Bollywood Movies

When glorifying stalking as ‘love’, filmmakers often rely on the argument from ‘freedom of speech’. However, given how mainstream and regional cinema impact people, this argument is ‘disingenuous’[3]. There has to be a distinction between objectively filming stalking or harassment scenes versus glorifying them. And the latter could quickly normalise harassment in real life.

To further study the issue, this paper is hinged upon a survey conducted on the age group of 18-27 years from different regions of Karnataka with a small sample size of 75 respondents. The motive of the study was to understand how people of the given age group perceive stalking and harassment in mainstream movies.  Of the total number of people who took the survey, as mentioned in annexure 1, 83.1% consider Indian cinema to glorify toxic representations instead of portraying honest and raw exhibitions with a projection of right and wrong.[4]

Findings: Using Content Analysis Method

This section uses the method of content analysis.[5] This study compares certain movies and their content. Subsequently, the participants were asked to list the films they thought glorified stalking-harassing tendencies. For this study, the most commonly named films by the participants are used as sampled films. In addition, the movies examined in this study are commercial films that have performed well at the box office.

Coding functions: For content analysis, the movies were categorised based on certain components.

  1. Social status of the stalker.
  2. Symbolism of virtue (the presence of the alleged protagonist)
  3. Glorification of pain and abuse on the victim (as per the role function)
  4. Subjected to censor the scenes by CBFC.

The researcher has divided the angle into two categories; yes (Y) or no (N).

Table 1


Sampled films


a. Social Status of the stalker.


b. Symbolism of virtue


c. glorification of pain and abuse on the victim


d. Subjected to censor the scenes by CBFC

 Dilwale Dulhania Le Jayenge 








Rehnaa Hai Terre Dil Mein 








Tere NaamYNYN
Kabir SinghYNYY


From above, in ‘Table 1’, code ‘a’ addresses the protagonist’s social status. After witnessing the stalking scenes in the sampled movies, the coders assigned a Y or N rating to the stalker protagonist’s social status.

Here, 40% of the sampled film protagonist stalkers are presented as lower in social status while with minimal or no education, without a nominal career. And 60% of the protagonist stalkers in the sampled films belong to good family backgrounds and high social status.

In code ‘b’, the stalker’s or abuser’s virtue is observed, which means that characters are depicted as heroes in these films. The response shows that 80% of the protagonist who are the ‘heroes’ in the film engage in certain behaviour patterns that suggest a wicked character.

Code ‘c’ is how the glorification of the abuser works in movies. Here, all the movies glorified the abuser, romanticising the pain of the victim.

In code ‘d’, except for Kabir Singh, all the other sampled films are certified without any censorship controversies. Kabir Singh, however, was indeed graded, but it was a matter of subject in the portrayal of substance abuse rather than its toxic behaviour pattern.

Repercussions of Glorifying Stalking and Harassment in Bollywood Movies and Regional Cinema 

The National Crime Records Bureau (NCRB) report released in January 2020 reported appalling numbers on stalking.  According to the report, in 2018, 9,438 cases of stalking, one every 55 minutes on average, were reported in India. These statistics are problematic because they were more than double the 4,699 cases, reported in 2014[6].

These figures often actualise in real life, and the glorification of harassment in Bollywood movies and regional cinema has been adding to the burgeoning crime against women. A popular example is an Australian court case against Sandesh Bagila, who worked as a security guard. Baliga was accused of stalking two women in Australia. In his defence, he had argued that he was inspired by Bollywood films and had no idea what he was doing was illegal. [7]

According to the Hobart Magistrates Court, he was influenced by vivid-romantic Indian cinema, where if a man pursues a woman for long enough, she falls in love. His lawyer, Greg Barns, told the court it was ‘quite normal behaviour’ for Indian men to pursue women similarly, which is why he didn’t realise that his actions could be criminal. [8]

How CBFC affects our viewing? 

Central Board of Film Certification is responsible is to strike a balance between art and its possible effect on society. However, it’s not that simple. Ideally, the censor board must protect freedom of speech and simultaneously mitigate any harm that such speech could inflict on the viewer. Whether or not it is able to strike a perfect balance is questionable.

The Supreme Court in K. A. Abbas vs The Union Of India & Anr[9] held,

“Censorship of films including prior restraint is justified under the Constitution. It has been almost universally recognised that the treatment of motion pictures must be different from that of other forms of art and expression.”

But it’s essential to understand that there have been instances where the CBFC had overstepped unnecessarily and was overtly moral, even when it wasn’t required. Its morality has often spluttered out when cutting Hollywood movies or movies that had intimate scenes. For example, it has gone far and beyond in cutting scenes of actors having alcohol in Ford V Ferrari.[10] However, when it comes to storylines that openly promote a criminal act, the Board has often given a clean chit.

It’s not to say that the CBFC is not essential.[11] There have been instances where the CBFC has been critical of scenes where films objectified the ‘victim’ and glorified crimes against women. One such example is the movie ‘Bandit Queen’. In response to a violent portrayal in the film, the tribunal had held:

“the scenes of nudity and rape and the use of expletive were in aid of the theme and intended not to arouse prurient or lascivious thoughts but revulsion against the perpetrators and pity for the victim.”[12]

Need for Reformation of Censorship Board n India:

If we trace back to the history of Indian cinema, the purpose of the censorship board was to let the freedom of speech and expression in art and literature be candid but within limits of reasonable restrictions. Thus, the role of the censorship board is to curb offensive scenes which glorify abuse rather than representing it with an intent to give out a message.

In Sivashankari vs The Superintendent Of Police, a seventeen-year-old girl had gone missing from the village of Nagapattinam. In this case, it was claimed that her stalker had sexually exploited her. Later, as the stalking continued, the girl married the stalker and reasoned that she was influenced by Tamil movies that had normalised the same.

Based on the case, it was pleaded that a film ‘NEW’, which had a similar storyline and got certified by the censor board, should be proscribed owing to its vulgarity. The Madras court hearing the matter held:

“Though guidelines have been issued for the Board of Film Certification to follow, lot of films which are put for public exhibition nowadays obviously do not satisfy these guideline”.

Therefore, the court continued:

“..we deem it appropriate to issue a direction to the authorities under the Cinematograph Act to strictly enforce the provisions of the Act and the guidelines issued therein.”[13]

In Aparna Bhat vs The State Of Madhya Pradesh,[14] the Supreme Court held:

“Social attitudes typically characterise this latter category of crimes as “minor” offences. Such “minor” crimes are, regrettably not only trivialised or normalised, rather they are even romanticised and therefore, invigorated in popular lore such as cinema.”

In 2018, the Kerala State Human Rights Commission directed the Central Board of Film Certification’s regional office, instructing them to implement a new regulation requiring movies to display a disclaimer anytime sequences depicting violence against women are shown. The CBFC agreed with the Commission.[15]

Although this endeavour is a step forward in altering dynamics, some are critical of its effect. Probably, the same wouldn’t have any immediate impact, but in the long run, it could oblige filmmakers to be more conscious when including such glorification.

Recently, in 2021, the Centre proposed amending the Cinematograph Act 1952 to include sections granting it revisionary powers and allowing it to re-examine films already certified by the CBFC. According to the Ministry, the proposed amendment implies that the Central government can overrule the Board’s judgment if it is warranted.[16]

However, according to filmmakers, these changes will render them powerless in the hands of the government, making them more vulnerable to threats, destruction and mob censorship.

Through the analysis of sampled films and judicial pronouncements, it is evident that there is a need for how films are censored. Understandably, under the new amendment, a film subjected to ‘super-censorship’ may succumb to the process and incur costs for the creators.

There are no clear answers when it comes down to the government’s meddling with freedom of speech. On the one hand, there needs to be a check on films that may glorify stalking. But, on the other, freedom of speech mustn’t be obliterated in the garb of censorship.

Should the new bill help structure the CBFC better? There’s no certainty. But there is a need for a mechanism to ensure that films that promote crimes against women are censored, even if it means revamping the CBFC. But the same must be done without the government’s oversight to avoid restrictions dictated by political whims.


From the analysis of this study, it is fair to point out that the Indian cinema often asserts stalking and harassment as love and heroism. The sampled films were the commercial movies that performed the highest number of hits and profits in theatres. Yet, they have the aspect of glorifying problematic tendencies, which in reality causes serious consequences.

It’s also fair to conclude that CBFC’s response to the crisis has been inadequate. Of course, the process of certifying a film must be seen from the standpoint of determining whether or not such representations would do severe harm to people’s minds. But CBFC itself is outlawing guidelines presented under the Cinematograph Act, 1952 by permitting such glorification.

We can hope for a set of more nuanced guidelines which understand how the mainstream affects people and penalises such portrayal accordingly. But at the same time, it must not hinder freedom of speech for other filmmakers.

Annexure 1:

Responses collected from the survey of participants aged 18-27 years old:


Variables                                                                        Agree %                         Disagree %                


The influence of movies on people’s lives                      96.1%                                  3.9%


Justifying the representations of stalker

conduct of the male lead in cinema                                 28.4%                                 71.6%

because the character is allegedly in love.


Glorification of stalking and harassment

through mere such representation                                   83.1%                                 16.9%

in Indian cinema.


Audience’s profound ignorance of

the disclaimers provided in the cinema.                         93.5%                                 6.5%



Annexure 2:


Sampled films:


Year               CBFC               IMDb rating               Title of the film


1995                   U                        8.1/10                      Dilwale Dulhania Le Jayenge


2001                   U                        7.6/10                      Rehnaa Hai Terre Dil Mein


2003                  U/A                     7.1/10                       Tere Naam


2013                  U/A                     7.6/10                       Raanjhanaa


2019                   A                         7.1/10                      Kabir Singh



[1] Eman Mosharafa, All you Need to Know About: The Cultivation Theory, 15 GJHS 23, 23 (2015),

[2] THE CINEMATOGRAPH ACT, 1952, § 5B, No. 37, Acts of Parliament, 1952 (India).

[3] Samira Sood, Art, life and Bollywood’s role in violence against women, THE PRINT, (Dec. 8, 2019, 12:08 PM),

[4] The researcher performed a survey, which is included in Annexure 1. A poll in which participants aged 18 to 27 were asked a series of questions on Indian film and portrayals of stalking and harassment. The data gathered from a young audience seeks substantially modern and fresh perseverance. The age group limitation was applied in this survey. Despite the vast range of responses, the majority of them had a similar perspective, i.e., misrepresentation of tolerance.

[5] Ms. N. Nazini & S. Arul Selvan, Imaging Muslim Women and Identity Formation Through Tamil Cinema in South India, 5 IJSR 1, 2 (2016),

[6] Shreya Raman, One Stalking Case Every 55 Minutes, Cases Still Underreported, INDIASPEND, (Feb. 12, 2020),

[7] Bollywood excuse helps Hobart stalker avoid conviction, ABC NEWS, (Jan. 29, 2015, 10:12 AM), .

[8] ibid

[9] K. A. Abbas vs The Union Of India & Anr, 1971 AIR 481.

[10] NewIndianXpress. The Bizarre Censor. The New Indian Express, The New Indian Express, 2 Dec. 2019,

[11] Priyanaka Ghai, Dr. Arnind P Bhanu, Censorship In India Vis-À-Vis Freedom Of Speech: Comparison Of The Extent Of Censorship Laws In India And Abroad, 7 JCR 436, 439 (2020),

[12] Bobby Art International, Etc vs Om Pal Singh Hoon & Ors, (1996) 4 SCC 1.

[13] Sivashankari vs The Superintendent Of Police, H.C.P.No.1573 of 2016.

[14] Aparna Bhat vs The State Of Madhya Pradesh, 2021 SCC OnLine SC 230.

[15] Sowmya Rajendran, Why the CBFC’s ‘Violence against women’ disclaimer for Malayalam films is a futile idea, THE NEWS MINUTE, (Apr. 30, 2018, 3:14PM),

[16] Srinivas G. Roopi, ETGov Explained: Why does the film fraternity oppose Cinematograph Act 2021 tooth and nail?, ET GOVERNMENT, (July 5, 2021, 5:30 PM),


Other References:

  1. Amy Sides Schultz, Julia Moore, & Brian H. Spitzberg, Once Upon a Midnight Stalker: A Content Analysis of Stalking in Films, 0 WJC 1, (2013),
  2.  Ekaterina Sivkova, Artists under pressure: Soviet filmmakers and censorship, RUSSIA BEYOND, (Oct. 9, 2014),
  3. Gautham Bhatia, The Costs of Censorship: The Cable Network Rules and the Banning of AsiaNet and MediaOne, INDIAN CONSTITUTIONAL LAW AND PHILOSOPHY, (Mar. 6, 2020),
  4. Madhavi Pothukuchi, All’s Fair in Love, including Stalking and Harassment, According to South Indian Cinema, VAGABOMB, (July 27, 2017),
  5. Poulomi Goswami, India: Glorification Of Stalking In Bollywood, MONDAQ, (Apr. 22, 2019),
  8. Swagat Baruah, Cinema on Trial: Doctrine of Prior Restraint in Censorship, 7 CULJ 23, (2018),
  9. Tejaswini Ganti, The limits of decency and the decency of limits: Censorship and the Bombay film industry, NYU SCHOLARS, (2009),

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