India’s film censorship regime is a much-maligned entity, frequently criticized for its overzealous moral policing and unabashed hypocrisy. In fact, the polemics on Indian film censorship generally revolve round sleaze, sensuality, sexuality, nudity, and permissiveness. It is then that fingers are pointed to a palpable legacy of ‘Victorian’ morality, prudishness and social conservatism. Critics bemoan that the Cinematograph Act 1952 – the Bible of film censorship in India – is crammed with too much baggage of the past. They argue, India’s film censorship machinery being an inheritance from her colonial period, some of its agenda remains an unwarranted spillover from that era.
This perception is only partially valid. A simple abolition of the ‘Victorian’ legacy from our film censorship legislation won’t in itself ensure a total disjunction between the ‘past’ and the ‘present’. The Indian film censorship regime reflects a much more problematic engagement between the colonial past and the post-colonial present. In fact, it reflects an intersection between continuity and change. On the one hand, the modes of content control characteristic to the colonial film censorship regime are very much with us today. On the other, its operational elements are going through continuous manipulation in response to emerging modes of address, creating a facade of change.
Censorship legislation was introduced in India under the aegis of Indian Cinematograph Act 1918. Then the1 British rulers were determined that cinema should serve, unflinchingly, their colonial interests. There was no indigenous film industry at that time and the canons of censorship targeted films imported from the West, especially the USA. The British wanted these films to create a rosy picture about the West and the Western people’s intentions in the colonies. The Provincial Censor Boards, constituted in 1920 and each one technically autonomous, had before them detailed guidelines regarding ‘sensitive issues’, ‘objectionable subjects’ and ‘forbidden scenes’ in ‘foreign’ films -actually meaning films from the USA. The administration, however, was not immune to the possibility of an Indian film industry emerging at some point of time and causing them more worries. To negotiate such an eventuality each of the Provincial Censor Boards in Bombay, Calcutta, Madras, Rangoon and Lahore was placed under the tutelage of the respective City Police Commissioner. Moreover, as an indigenous film industry began to emerge in the mid-1920s, the bureaucracy started aligning themselves more with the censorship decisions and making their presence felt in major censorship matters. They did this through the exercise of executive prerogatives provided for in the Indian Cinematograph Act 1918. The idea was twofold: to bully the Boards into submission, and subjugate the unhindered development of theme and content within the fledgling film industry. After some time, the frequency of bureaucratic interventions decreased, only because the film censorship system by then had become sufficiently subservient to the will of the Government. To keep matters totally under bureaucratic control, the censorship decisions were put beyond judicial scrutiny, that is, made non- justiciable.The philosophy of film censorship in pre-independence India evinced three basic parameters:
- to deny the Indian audience any access to communist or socialist ideals (‘propaganda’ in administrative language) reflected in the Soviet cinema;
- to ensure that the spirit of freedom and independence did not reach the audience of a colonized country regularly through the American films; and
- to prevent the crystallization of nationalist paradigm in the Indian cinema.
It is however significant that the British rulers chose to foreground “the safety of the audience and the prevention of degrading or moral performances” in order to camouflage their real, that is political, intentions.
There was certainly no need for the rulers of independent India to carry forward this legacy. But they surprised everybody by choosing to retain the system of film censorship in the post-colonial era. As it later transpired, it was essentially an appropriation for an eventual reconstruction. There was no change, let alone improvement, in the ‘official’ perception about the status of the film medium. It was however further complicated by the enunciation of a ‘political’ perception, which was totally different from the one that emerged in the colonial era. The new-found rhetoric about rationality, freedom, justice, right, modernism, progress and development flaunted by the national(ist) leaders of India with gay abandon, were not applicable to the film censorship machinery. Cinema remained equally vulnerable to administrative pressures and susceptible to the politicians’ malice in the new era. However, the manner in which these negative perceptions were enunciated was far removed from that prevalent during the colonial era. If the former bore a sure stamp of coercion, if not an out and out repression, an assured swiftness and deft manoeuvrability characterized the latter.
By 1952, the post-colonial infrastructure for film censorship was put in place. It followed a series of debates, moves and counter-moves regarding a possible reorientation of the system of film censorship in the post-independence era. Since the days of the interim government (1946-47), the film trade had begun to express itself strongly in favour of a centralized system of film censorship, ostensibly with a view to weeding out regional differences in judgements. It was a period when the industry was increasingly coming under the sway of the ‘independent’ producers. They often had access to dubious sources of funds and indulged in speculative investment with an eye on the fast buck. They found their peers in the distribution and exhibition sectors also. They all undertook speculative activities often with utter disregard for normal laws of market transactions. They eventually forced most of the established/conventional operators out of business, throwing the trade into complete chaos and disarray, and also vitiating the atmosphere of the industry. Most of the films, made under the tutelage of the ‘independent’ producers, were stuffed with ingredients they thought would have ‘mass’ appeal. They however pleaded for ‘slight’ indulgence from the Censors in conformity with the spirit of freedom permeating the country. And their demand for a centralised censor board was a ploy to secure the minimisation of possible obstacles to their films. They further demanded that such a board should not be “subject to revision by the Provincial Government unless for reasons of grave danger to public security”.
The majority of the emerging leadership of new India was however against the idea of treating film ‘entertainment’ with lenience. They associated it with harmful western influence that needed to be purged, or at least checked. Their actions and utterances gave enough indications that the sanctity of the principles of morality and behaviour “as laid down by our forefathers” would be repeatedly invoked in matters relating to the exhibition of films in this country after independence. But there was an even more significant pointer to the possible use of censorship machinery in the post-colonial era. The bureaucracy was all for the adoption of a stricter code censorship. They complained of “too much frivolity” in Indian films of the period and demanded their adherence to a more rigorous standard of moral to justify their claim as a medium of entertainment and education.
Several meetings were held between the bureaucracy and the representatives of the industry. They discussed methods to be adopted with a view to minimising the difficulties that might be caused to the trade. While both parties agreed that an improvement in the moral and ethical standards in films was indeed a priority, divergence arose over the manner of execution and method of accomplishment. The industry advocated an immediate overhauling of the structures and a change in the philosophy of film censorship as well. But the entente of the political leaders and the bureaucracy was in no mood to oblige them and bid its own time. On August 29, 1949, the Government of India appointed a Film Enquiry Committee under the Chairmanship of Sri S K Patil, a member of the Constituent Assembly. The directives before the Committee were :
- to examine the growth and organisation of the film industry in India, and to indicate the lines on which further development should be directed, and
- to examine what measure should be adopted to enable films in India to develop into an effective instrument for promotion of national culture, education and healthy entertainment.
While most people expected the Committee to come down heavily upon the industry, their report  took a surprisingly condescending attitude despite all-round clamour for a stricter control. The Committee were in fact all praise for the achievements of “an industry which has grown to such proportions on its own, without either State support or patronage and in the face of foreign competition, on terms which were certainly not much to its advantage”. The Committee also expressed confidence in ‘’the competence of the industry itself to regulate and control”.
These were all part of a policy of tactical appeasement. It also included the introduction of two categories of censor certificate [‘U’ for universal exhibition and ‘A’ for exhibition restricted to adults only (people above the age of 18 years)] and abolition of the functional autonomy of the Provincial Censor Boards of the pre-independence era. In 1951 they were brought under the unified command of a Central Board of Film Censors1. Centralization of film censorship was a direct affront to the spirit of federalism enshrined in the Indian Constitution of 1950. But this was an indication that the leaders of independent India were more committed to building a unitary State structure than creating a genuinely federal system. It was moreover a fulfilment of their political agenda regarding cinema. Like their predecessors, they were also keen that cinema should serve their broad political objectives, which involved projects for democracy, citizenship and nationalism. But, unlike the colonial administration, they preferred a uniform code of control to be formulated by the central bureaucracy, and exercised by the CBFC. The reconstituted Regional Censor Boards, subordinate to the CBFC and with considerably reduced power, were but an insignificant concession to the concept of federalism. The Cinematograph (Censorship) Rules 1951 were consequently framed, setting out the composition of the centralised Board and its modus operandi.
Such machinations of the government worked brilliantly as the industry-people were lulled into complacence. They were expecting further concessions when in July 1952 the Indian Cinematograph Act 1952 was slapped on them. The new legislation, repealing the Indian Cinematograph Act 1918, was far more elaborate as well as explicit than its predecessor. It also revalidated the Cinematograph (Censorship) Rules of 1951 in order for these to continue to govern the operations of the CBFC. Also a four-page document was prepared and published. Titled “Directive to Examining Committees regarding the principles to be observed in determining whether a film is or is not suitable for public exhibition”, it contained a detailed list of objectionable matters in films, ‘as it is desirable that there shall, as far as possible, be a uniform standard for determining whether a film is suitable or not for unrestricted public exhibition or for public exhibition restricted to adults’. While, by transference and selective adoption, the inherent philosophy of film censorship thus remained distinctly similar to that enunciated during the colonial period, important changes were wrought in the operative principles of the new dispensation. These were bound to have far-reaching implications. The centralisation of the censorship authority meant that the State (here represented by the Central Government) would need to monitor the working of only one body to carry out its restrictive agenda on cinema.
This would in effect ensure “uniformity” in matters of regulation and control. The Central Government of independent India also brought unto itself the major onus of state action. The State Governments were left with the task of bringing to the notice of the CBFC (and in effect the Central Government) instance(s) of violation of the censorship diktat.
Even more significant was the change brought about regarding the choice of personnel to be associated with the task of film censorship. The Regional Boards of the British period comprised representatives drawn from specified government agencies and social interest groups. While this was certainly no guarantee for rational judgement, it had at least set out certain norms and ‘objective’ standards regarding the composition of the boards. But the 1952 Act, by revalidating the Cinematograph (Censorship) Rules 1951, provided legitimacy to a totally arbitrary method for the choice of non-official persons. This left too much discretionary power with the government in this regard. There was no mention of a set of norms or ‘objective’ criteria for the nomination or appointment of personnel for this purpose. Specific qualifications were not prescribed either for the appointment of the Chairperson, or the nomination of the members of the CBFC or the Advisory Panels. The Chairperson was to hold a statutory position, but the appointment was to be without consultation of the Union Public Service Commission. As for the members nominated to the CBFC or the regional advisory panels, it was only expected that they would possess sufficient education and cultural competence to deal with film censorship matters. But the parameters of ‘sufficiency’ and ‘competence’ were not outlined. It was serious matter. While examining a film, the CBFC was to act quasi- judicially, if not judicially. It had to carefully examine the scenes and their possible impact on the society and come to a judicious decision regarding the fate of a film. And a court could correct its decision or order, as it was a “body of persons having legal authority to determine questions affecting the rights of subjects”. Thus by implication, the criteria for nomination to the Board or the Advisory Panels should have entailed knowledge about human rights or democratic rights. But the Government was the least bothered about these. In reality, the nomination to Censor Boards became a means to distributing political/bureaucratic patronage. Only the Regional and other subordinate Censor Officers were to have specified qualification, as they would be drawn from the Class I cadre of All India Central Services. Thus, in effect, film censorship was reduced in effect to an executive exercise, based entirely on principles laid down by the bureaucracy.
The government got away with all such machinations despite Article 19(l)(a) in the 1950 Constitution that guaranteed each individual citizen right to freedom of speech and expression. But this was not to be an absolute right. Exceptions were granted under Article 19(2) that only defined the limits of tolerance and subsequent state action regarding the right to freedom of speech and expression. It did not specify the nature of such action. Only by inference and common prudence it was held that the enactment of legislation(s) with executive powers to “regulate” the freedom was permissible, provided the exercise of those powers were restricted to grounds specified in Article 19(2). In 1951 there were strong apprehensions in the government quarters that the Supreme Court would strike down the provisions for film censorship contained in the Cinematograph Act 1918, which was still in force. In fact the Supreme Court at that point was striking down censorship provisions not restricted to grounds specified in Article 19(2). In a prompt reaction to this development, the government enacted the Constitution (First Amendment) Act 1951. It fundamentally altered the spirit and scope of the original Article 19(2). The amended Article 19(2) now provided for the imposition of “reasonable restrictions” on the exercise of rights conferred by Article 19(1), including right to freedom of speech and expression. This First Amendment of Indian Constitution thus paved the way for the passage and unhindered operation of Cinematograph Act 1952 containing precensorship provision.
Why did cinema continue to remain so vulnerable to political/bureaucratic manipulation in the post-colonial period? Of course one can attribute this to the lack of modernist outlook of our political elite. Ravi Vasudevan has suggested that this phenomenon compelled cinema to lag behind in the overall formation of national cultural institutions, like the National Gallery of Modern Art, the Lalit Kala Akademi, the Sangeet Natak Akademi or the Sahitya Akademi. But this, I feel, is only a part of the whole story.
The immediate aftermath of India’s independence witnessed the cementing of the alliance forged between the political leadership and the institutional legacies of colonialism, especially the civil bureaucracy and the police – a process that began during the interim government (1946-47) and persisted through the dominion period (1947- 1950). This not only ensured the continuation of the British India’s unitary State system but also facilitated intemalisation of authoritarian methods by the Indian politicians in power on the pretext of better governance. At that time it did not attract much public criticism, owing to the prevalent political climate. India earned her independence after a sequence of catastrophic events lasting almost a decade – the Second World War (1939- 45), the communal riots (1946-47), the Partition (1947) and the dispute over the accession of Kashmir to India (1948). The adverse socio-economic impact of the World War, the human cost of the riots, the political implications of territorial consolidation after a bloody Partition and the complex military engagement in Kashmir together with its diplomatic fallout had a traumatic effect on the infant nation. In this situation the Indian rulers could easily dispense with certain crucial components of classical democracy on the pretext of discipline, stability and social progress.
The post-colonial Indian society and polity also witnessed the emergence of what Partha Chatterjee has termed as a ‘political society’ to encompass the forms of mobilization around collective identities. ‘Political society’ is composed of parties, movements and non-party political formations. On one hand, such formations constantly superseded, or sometimes usurped, the autonomous role of the individual in the society. On the other, they came in constant conflict with the norms, institutions, democratic rights and entitlements so characteristic of a liberal civil society. In any resolution of crisis, the logic of reason was constrained by the logic of numbers. The legacy of mass movement during the pre-independence days completely overwhelmed the process of social engineering in the post-colonial Indian society.
The leaders of independent India sought to live up to the pressure of mass aspiration by propagating a complex fabric of ideological concepts like nation-state, nationalism, modernity and progress as being the crucial element of a post-colonial social formation. They were perceived as facilitators of a homogeneous post-colonial society, to be groomed on the basis of democracy as its political ideology and planned development as its economic agenda. But this drive towards homogeneity floundered around the choice of a cultural policy. Ambiguity between rationality and scientific temperament on the one hand, and religious orthodoxy and traditionalism on the other completely disoriented the cultural formation in post-colonial India. Moreover, there was hardly any significant effort to encourage the plurality and diversity of cultural practices. True to this principle, the institutions of cultural formation were all based in New Delhi, guided by unitary policies and practices. Cinema epitomized this confusing, problem-ridden scenario. Perhaps more so because of its technological nature in contrast to the more conventional art forms. The burden of its stigmatised existence, a legacy of the colonial period, further problematised its cause.
The post-colonial Indian society condemned cinema to an ambiguous position, jeopardizing its autonomous journey and search for homogeneity.
There were diverse pulls and pressures on this medium from different quarters. Since the 1950s, an elaborate scenario emerged around the so-called pan-Indian Hindi cinema, advocating entertainment’ under the tutelage of speculative investors. Encouraged by its so-called pre-eminence as the vehicle of’official’ language, it began to hog the limelight, often in a manner disproportionate to its share of output. Even the adamant regionalism of the south Indian states reconciled itself to the regular production of Hindi-remakes of successful local language films for an all-India market. This cinema was characterized by a pseudo- modernist melodramatic structure, which eventually became the model for regional commercial cinema also. But the influence of cinema literacy in the more enlightened sector of the society gave rise to a different brand of film culture. Cinema was acknowledged as a serious form of expression, with a resonant voice, discursive text and responsive audience. Thus evolved a modernist paradigm for cinema, with an emphasis on realism. Some people assigned a pro-active, developmental role to cinema, preferring factual construction, analytical paradigm and direct address. Their demand was for documentary cinema. Against these proponents were the antagonists of cinema, who weighed this medium with jaundiced looks, treating it as harmful for the society. And above them all was the State, which wanted cinema to foster a culture of responsible citizenship.2 While some of these articulations were indeed very well structured, emphatic and organized, the majority was rather intermittent, haphazard, and scattered over speeches, leaflets, public communications, private discussions and even stray remarks. Yet, their summation produced a synergy, ultimately turning into a substantial discourse around the post-colonial Indian cinema. Within this discourse, the non-official, public voice overshadowed the official voice of the State. As a result, the malice and apathy exhibited by the political elite were more than offset by a remarkable upswing in the popularity of cinema. There was however an exception to this general pattern of discourse around cinema in the post-colonial India. And that involved film censorship. In this area, the official voice of the State was more assertive than the public voice. The appropriation of the film censorship machinery of the pre-independence days is a sure manifestation of this assertiveness. It is significant that the basic framework for this machinery was finalized even before parliamentary democracy started functioning properly in independent India. The First General Elections, conducted on the basis of universal adult franchise, were held between 25 October 1951 and 24 February 1952. The first session of the newly constituted Indian Parliament could not have been convened before March 1952. The Indian Cinematograph Act 1952 had received Presidential assent on March 21, 1952 and came into force with effect from July 12, 1952.
Remarkably, not only did the citizenry not resent the continuation of film censorship in a post-colonial democratic India, but they also felt secure in this arrangement. The society by and large accepted the State-projection of this arrangement as the best method for neutralizing the pulls and pressures that the post-colonial Indian cinema was being subjected to. Perhaps we can even suggest that the censorship regime offered them a mechanism by which to defend themselves against cinema’s supposed attack on their privacy, settled habits and thoughts. Different interest groups discovered elements of merit or virtue within the censorship machinery for their respective constituencies. The State, on its part, started acting as an arbiter, and also a manipulator, of popular perception about cinema.
This in itself was a paradigm shift. While film censorship in the colonial era represented a unidirectional act of coercion devised by the State, post-independence it was quite perceptibly transformed into a more diversified, and multilateral, power- relation. It began to revolve round an antagonism between the limits of freedom of expression aspired by a technological medium driven by modernism and the exercise of power defined by class, sector or group perceptions and interests. Seen from the perspective of the State, this exercise of power started manifesting a particular brand of teleology couched in legal and administrative jargon. The citizenry on the other hand participated in this exercise of power armed with a different brand of teleology full of value-loaded moral or ethical terms. The former unfolded in January 1951, when the then Minister of Information and Broadcasting, Mr. R. B. Diwakar, characterized the newly formed Central Board of Film Censorship as a “dignified effort to model an effective medium of healthy entertainment, national culture and mass education”. A public petition, presented in 1954 to then Prime Minister Jawaharlal Nehru, urging him to curb the evil influence of films, epitomizes the latter. 13,000 women, mostly housewives, signed it. It evoked an ambivalent response from the influential Prime Minister. While he emphasized the role of cinema as a vehicle of modernism, he also advocated some amount of social control to ward off its bad effect. But the outcome is not so important in this context as its import. The very fact that the Prime Minister chose to respond to ordinary citizens on this issue was in itself a new development. It not only brought the citizenry within the domain of film censorship but also legitimised their exercise of power. Before independence, the colonial administration simply denied so much space to their Indian subjects.
Film censorship regime in post-colonial India thus turned out to be not quite an arrangement through which the State imposed repression overriding popular dissent It rather came to reflect certain ideological compromises reached between social forces in an epoch of transition. It was indicative of the relative power and authority of different segments of the society, including the members of the State machinery. More importantly, it gave rise to a terrain for the play of power that would start creating and recreating rules, evolving parameters of debate, categories and subjects. In other words, it inaugurated a discourse of censorship, reconciling its apparently incongruous cohabitation with the constitutionally sanctioned right to freedom of speech and expression by teleological arguments. This reconciliation was given the stamp of constitutionality in 1959. In the most significant amendment to the Cinematograph Act 1952 to date, the State incorporated certain guiding principles for the certification of films. It read: A film shall not be certified for public exhibition if, in the opinion of the authority competent to grant the certificate, the film or any part of it is against the interests of the security of the State, friendly relations with foreign States, public order, decency or morality, or involves defamation or contempt of court or is likely to incite the commission of any offence.
Significantly, it replicates the “reasonable restriction” clause of the amended Article 19(2) almost word for word to prepare the ground for the prevention of exhibition of “objectionable” films. Once such arguments began to emerge, and began to be accepted, it created opportunities for camouflaging the political essence of film censorship in post- colonial India.
In course of time, the exercise of power around film censorship has acquired a broader spectrum and many more articulations than was the case before independence. But the State, the media, the citizenry and even the judiciary go on highlighting its ‘moral’ parameters. It is also no accident that the media hype and public debate that raged around the suitability of films like Fire, Kama Sutra, Bandit Queen, Queen Elizabeth for the ‘Indian’ audience revolved round ‘moral’ issues and avoided more important questions of gender or sexual politics. And the essence of the judicial perception was outlined in a landmark Supreme Court judgement (1970) vindicating the justification and reasonableness of film censorship in India on moral grounds.3 It all appears like a collective endeavour.
Yet, in spite of the disproportionate emphasis on moral implications of film censorship in this country, political statements continue to be made around film censorship. The State nowadays promotes jingoist feature films like Roja, Gadar, Border or Sarfarosh, which incite the audience to shout anti-Pakistan slogan. But Anad Patwardhan, the maker of the documentary Jung aur Aman, has to seek judicial intervention against the CBFC for questioning nuclear politics of both India and Pakistan, and preaching a rational, pacifist approach. The State allows Sathya, which depicts indiscriminate killing of ‘gangsters’ at the hands of police. Yet a documentary like Aakrosh is refused certificate for “depicting violence” in post-Godhra Gujarat! All the mainstream films mentioned above have thrived with media and popular support. However, these are not recent developments. Way back in 1964, the late Vijay Anand made a jingoist film Haqquequat, castigating the Chinese “invaders”. This was a fallout of the Sino-Indian border conflict. The film received unprecedented State patronage and popular/media support. In 1971 Satyajit Ray had made a documentary Sikkim, on the life and culture of then independent Himalayan kingdom. But after India annexed the kingdom in 1976, the film fell foul of the official version about the new possession and was never cleared for public exhibition thereafter. It hardly caused any ripple. So, political manipulation of film censorship encompasses not simply refusal/withholding of censor certificate to ‘objectionable’ film(s), but deliberate promotion of ‘favourable’ films. And as is evident from the above, such actions have been perpetrated by successive regimes irrespective of their ideological bias, to be supplemented by popular/media support or apathy.
Significantly, the political discourse of film censorship nowadays transcends the conventional framework of monitoring and control by state agencies. We have seen how political vandals sought to stall the exhibition of the film Fire. While they had limited success in this endeavour, they went the whole hog to abort the shooting of Water through realpolitik. All this was for allegedly trying to portray ‘Indian’ women in a
‘derogatory’ manner. Or take the controversy surrounding Ek Chhoti Si Love Story. Its heroine wanted the film to be withdrawn from public exhibition, invoking her right to privacy and even seeking legal protection. She was wary of the degree of exposure indulged in by her body-double in the film. The matter was finally settled out of court, but not before it degenerated into an unabashed exhibition of political clout by the concerned parties. And in February 2004, the Government of India decided to refuse entries of Indian films in the Mumbai International Film Festival for short films unless accompanied by censor certificate. This unprecedented move has not only deprived many critical documentaries from gaining international exposure, but also violated standard norms.
It is high time that we woke up to the different manifestations of the political manipulation of film censorship in India. For these reflect the true potential of this important social phenomenon. Film censorship in India is no more an operational restriction on a medium with the help of administrative instruments. It is a siege on the collective psyche of the Indians, who have responded positively and enthusiastically to the images woven by moving pictures. It is a siege on the cultural formation of the 20th century Indian society of which cinema has been a crucial element. And finally it is a siege on the political rights of the Indians, at least the cinema-loving ones, on the pretext of societal interest.
- This nomenclature was changed to Central Board of Film Certification in 1983, without any qualitative change in the function and responsibility of this body. A further appendage to the censorship machinery was provided in the form of a Film Certification Appellate Tribunal or FCAT in 1991. This Tribunafr was set up to act as an arbiter in disputes between filmmakers and the CBFC. But the FCAT’s agenda and the CBFC’s powers are still subservient to the will of the State.
- The well-known film personality Marie Seton came to India in the late-1950s, at the behest of both the Government of India and the UNESCO, to advise on film appreciation. She produced two monographs, titled Film Appreciation: the Art of Five Directors and Film as an Art and Film Appreciation.
- Holding that “censorship imposed on the making and exhibition of films is in the interest of the society”, the apex court ruled “censorship in India (and pre-censorship is not different in quality) has full justification in the field of exhibition of cinema films. We need not generalise about other forms of speech and expression here for each such fundamental right has a different content and importance.”