The Allahabad High Court, Lucknow Bench, on September 2, 2025, dismissed a writ petition seeking to restrain the release of the film “Jolly LLB 3” and the removal of its song “Bhai Vakeel Hai” from online platforms. A Division Bench comprising Justice Sangeeta Chandra and Justice Brij Raj Singh, after reviewing the film’s trailers and song lyrics, found no objectionable material warranting judicial interference.
The Court delivered the judgment in the case of Jay Vardhan Shukla & Another v. Union of India & 6 Others. The primary legal issue was whether the court should issue a writ of mandamus to prevent the film’s release and Censor Board certification based on allegations that its promotional material was derogatory to the legal profession and judiciary. The petition was dismissed.
Background of the Case
The writ petition was filed by Jay Vardhan Shukla and another, seeking several directions from the court. The petitioners prayed for an order to restrain the film’s director (Respondent No. 3), actors (Respondents No. 4 and 5), and producer, Fox Star Studios India Private Limited (Respondent No. 7), from “releasing, exhibiting, distributing or screening the film ‘Jolly LLB 3’ in any form.”
Furthermore, the petitioners sought a directive for the Union of India (Respondent No. 1) and the social media intermediary (Respondent No. 6) to immediately remove the song “Bhai Vakeel Hai” from all digital and social media platforms. They also requested the Central Board of Film Certification (CBFC, Respondent No. 2) to revoke any certification granted to the film and to formulate stricter guidelines to prevent the certification of films that demean the judiciary and the legal profession. A final prayer sought a public apology from the director and actors for the alleged “derogatory portrayal of the legal fraternity.”
Arguments of the Parties
The counsel for the petitioners, Rishab Khare and Anadi Chitranshi, argued that the trailer of “Jolly LLB 3” depicts the legal profession in a derogatory manner. It was contended that the respondents, for profit, “have tried to shown the judiciary in a scandalous manner; thus attempting to lower its dignity in the eyes of a common man, which amounts to the Contempt of Court and defamation of the institution.” The petitioners asserted that the widespread circulation of the trailer and songs on platforms like YouTube was prejudicing the minds of practicing advocates and causing “grave injury to the judiciary.”
The petitioners further argued that the CBFC had violated its statutory duty under Rules 5-A and 5-B of the Cinematograph Act, 1952, by permitting material that scandalizes the judiciary. They claimed the portrayal violated the dignity of advocates as officers of the court, affecting their ability to perform their duties under the Advocates Act, 1961, and discouraged individuals from joining the legal profession.
In response, S.B. Pandey, learned Senior Advocate and Deputy Solicitor General of India, appearing for the Union of India and the CBFC, raised a preliminary objection to the maintainability of the writ petition. He submitted that a writ of mandamus cannot be issued unless the petitioners first make a representation to the concerned authority. In this case, the petitioners had not approached the CBFC or any other authority under The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, before filing the petition in the High Court. He argued that there was no refusal or inaction on the part of the official respondents to perform their statutory duties.
The petitioners countered that the remedy under the 2021 Rules was “inefficacious” as they would have to first approach the publisher or social media intermediary, which would not be effective given that the trailers had already garnered three crore views on YouTube.
Court’s Analysis and Decision
The High Court first addressed the preliminary objection raised by the Deputy Solicitor General. The bench observed, “We find from the petition that the petitioners have not yet approached any authority as given under the Rules, 2021. We find the preliminary objection raised by the learned Deputy Solicitor General of India to be of some substance.”
The Court then proceeded to examine the material in question. After a direct review of the promotional content, the bench made a clear finding on the merits of the petitioners’ allegations. The judgment states, “We have also gone through the alleged three official trailers/teasers of Jolly LL.B.-3, in which according to the petitioners, are derogatory to the legal profession and tend to lower the dignity of the Court in the eyes of a common man and we did not find any objectionable matter to warrant interference by this Court.”
Addressing the controversial song, the Court concluded, “We have also gone through the lyrics of the song ‘Bhai Vakeel Hai’ and we do not find anything which may interfere in the practice of the legal profession by genuine Advocates.”
Based on these findings, the Court dismissed the writ petition. No order as to costs was made.
