Two Laws, One Film: How India Regulates a Movie Differently in a Theatre and on a Phone

Article summary

The removal of the biographical film Satluj from ZEE5 in July 2026 — reportedly on security grounds and under obligations flowing from the IT Rules, 2021 — has revived a structural question in Indian media law: the same film is governed by two entirely different legal regimes depending on the screen it plays on. A theatrical release requires prior certification by the Central Board of Film Certification under the Cinematograph Act, 1952; the makers of this film had applied in 2022 under the title Punjab 95, declined the 127 cuts the CBFC proposed, and released it online instead. Streaming platforms, by contrast, face no pre-certification at all — they operate under a three-tier self-regulatory architecture in Part III of the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, backstopped by the government's post-publication blocking power under Section 69A of the IT Act, 2000. The Karnataka High Court declined in 2019 to read OTT into the Cinematograph Act, and the Broadcasting Services (Regulation) Bill that would have harmonised the two was withdrawn in 2023. For UPSC, this is the cleanest available case study on reasonable restrictions under Article 19(2) and on regulatory arbitrage between statutes.