Documentary on Gang Culture Cannot Be Banned on Mere ‘Law and Order’ Apprehensions: Punjab & Haryana High Court Upholds Free Speech, Clarifies Scope of ‘Public Order’
Case Name: Zee Entertainment Enterprises Limited v. Union of India and Others
Date of Judgment: 11 May 2026
Citation: CWP-13221-2026
Bench: Justice Jagmohan Bansal
Held: The Punjab and Haryana High Court held that a documentary discussing gang culture and criminal networks cannot be blocked merely on speculative apprehensions of glorification of gangsters when the content, viewed as a whole, neither promotes crime nor incites violence. The Court ruled that the Central Government’s advisory restraining release of the documentary failed to satisfy the statutory requirements under Section 69A of the Information Technology Act, 2000, as no valid satisfaction regarding threat to public order had been recorded. The Court further emphasized that criticism or examination of criminal activity cannot automatically be equated with glorification of crime.
Summary: The writ petition was filed by Zee Entertainment Enterprises Limited challenging communications dated 23.04.2026 and 24.04.2026 issued by the Union Government advising the OTT platform not to release a documentary initially titled “Lawrence of Punjab.” The advisories were issued after concerns raised by Punjab Police and central security agencies alleging that the documentary could glorify gangster culture, gun violence, and criminal lifestyles, thereby affecting public order and ongoing criminal trials.
The State of Punjab relied heavily upon earlier interim orders passed by the High Court in pending PIL proceedings directing removal of interviews and online content glorifying gangster Lawrence Bishnoi. The State argued that the documentary title itself demeaned Punjab and had the potential to attract young minds towards criminal activities. The Union Government contended that it had acted in exercise of powers under Sections 69A and 79 of the Information Technology Act, 2000 after receiving inputs from Punjab Police and a central security agency warning of possible law and order implications.
On the other hand, Zee Entertainment argued that the documentary was not based upon a single gangster and merely compiled publicly available material relating to multiple gangs and criminal networks. It was submitted that the documentary sought to criticize and expose the destructive consequences of gangsterism rather than glorify criminals. During the hearing, Senior Counsel appearing for Zee assured the Court that the expressions “Lawrence,” “Bishnoi,” and “Punjab” would be removed from the documentary title, posters, and trailers before release.
Justice Jagmohan Bansal personally viewed the documentary and concluded that it was not a cinematic glorification of gangster life but rather a documentary compilation featuring opinions of retired police officers, journalists, and advocates. The Court specifically observed that none of the speakers glorified crime or criminals and that the overall message conveyed that the lives of gangsters are short-lived and destructive not only to themselves but also to many innocent persons.
The High Court held that the impugned advisory failed to satisfy the mandatory requirements of Section 69A of the Information Technology Act because the competent authority had merely reproduced statutory phrases such as “public order” and “incitement” without recording any substantive satisfaction demonstrating actual necessity to block the documentary. The Court further observed that the earlier High Court orders relied upon by Punjab were confined to removal of interviews glorifying gangsters and did not prohibit all content discussing gang culture.
Relying upon Ram Manohar Lohia v. State of Bihar, the Court elaborated the distinction between “law and order” and “public order” and held that every apprehension of disorder does not amount to disturbance of public order. The Court noted that similar crime-based films and web series already exist in the public domain and mere depiction of criminal activity cannot automatically justify censorship.
The Court also relied upon Director General, Directorate General of Doordarshan v. Anand Patwardhan to reiterate that a film or documentary must be assessed as a whole from the standpoint of an average and reasonable viewer rather than by isolating selective portions. Ultimately, the High Court concluded that the documentary was not likely to incite criminal conduct or disturb public order.
Decision: The writ petition was allowed. The Punjab and Haryana High Court set aside the impugned advisory restraining release of the documentary while directing that the documentary title, trailer, and promotional material shall not contain the expressions “Lawrence,” “Bishnoi,” or “Punjab.”