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Delhi High Court raises questions on the use of ‘Shoorveer’ song in Mirzapur movie in the context of the heightened violence in the city

Delhi High Court had expressed concern over the use of the song Shoorveer in a violent scene of Mirzapur: The Movie, saying that its use in the specific situation did not “prima facie” seem “in good taste”. While considering a PIL on the song in the movie, the Court also asked the question, “We have come to a situation where we are revering violence?”

Chief Justice Devendra Kumar Upadhyaya and Justice Tejas Karia were presiding over a petition filed by Prashant Kumar Singh, challenging the song, which was referred to as “Shoorveer” and which is allegedly a tribute to the historical warrior Maharana Pratap, as background music for a violent scene featuring fictional gangsters.

The petitioner argued that the song’s allusion to Maharana Pratap’s virtues of courage, sacrifice and honour was being juxtaposed with a made up story of gangsters and violence. The plea states such conduct may lead to the creation of an undesirable association of a revered historical figure with characters of criminality and may dilute the cultural context of the song.

The petition was for the removal or replacement of the track from the above climax of the film. It also suggested the general question of guidelines to be laid down about the use of songs of historically or culturally great personalities in movies.

But the film’s producers didn’t agree with the meaning. Their counsel argued that the title was used as props to the climax which represents the fight between two groups and there was no attempt to make any comparison with Maharana Pratap. The producers also stated that this isn’t the scene where the characters are singing the song.

At the hearing, Court was told that the producers themselves had approached the Central Board of Film Certification (CBFC) and suggested that they need to make some changes in this film as otherwise it would not be able to exhibit after they received its 13A certificate.

CBFC had told the Court that it would decide the proposed modification in a week. The issue is set for further hearing on September 24, 2026.

The development is important because a film’s certification and modifications typically would be governed by the statutory regime for the exhibition of films. The mechanism of certification under the Cinematograph Act, 1952, has the power to review films taking into consideration the statutory provisions relating to the public exhibition of films. The Cinematograph (Certification) Rules, 2024 also detail the process for making changes that can be suggested and examined.

A pivotal constitutional conflict between freedom of artistic expression and cultural concerns arises in the case. Article 19(1)(a) guarantees freedoms of speech and expression, including expression in art and cinema, but it is subject to the restrictions in Article 19(2) that are reasonable.

In parallel, the Court’s comments suggest that context is a key consideration when artistic content is juxtaposed with drawings of violence or crime. The Court has yet to make a final determination that the song’s use infringes on any fundamental right or any statute.

The Delhi High Court proceedings bring into focus the tricky line between creative freedom and cultural sensitivity. The petitioner’s complaints centre on the implied message that juxtaposing a historical homage to the dead with fictional violence, but not the other way around.

Notably, the Court’s comments are at a stage called ‘interlocutory’ and are not yet final rulings on whether the movie is ‘glorifying’ violence or ‘misrepresenting’ Maharana Pratap. In fact, the instant question has shifted to the CBFC, which will be called upon to take a decision on the proposed change within a week. The case will consequently be important in shaping the interpretations of courts and certification authorities regarding artistic decisions which raise issues of cultural symbolism and violence representation.

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