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Karnataka High Court refuses to stall ‘Dhurandhar 2’ screening over plagiarism claims

The Karnataka High Court was hearing a filmmaker’s plea challenging that the Dhurandhar 2 movie was based on his script ‘D Saheb’. 

Dhurandhar 2, Dhurandhar The RevengeThe Karnataka High Court noted that the filmmaker is alleging that the movie is based on his script ‘D Saheb’.

Karnataka High Court Dhurandhar 2 news: The Karnataka High Court recently dismissed a filmmaker’s plea alleging that the movie Dhurandhar 2 was plagiarised from his script ‘D Saheb’, holding that the Central Board of Film Certification  (CBFC) is not responsible for investigating claims of script theft before issuing a certificate.

Justice K S Hemalekha was hearing the plea of Santosh Kumar, who was seeking directions to the CBFC to cancel the certificate granted for the screening of the Ranveer- Sara starred film.

He further prayed to restrain the Dhurandhar 2 screening across platforms, alleging that the said movie is a plagiarised version of his original script.

“There is no statutory duty for the board (CBFC) to investigate allegations of script theft before issuing a certificate,” the April 22 order read.

Justice K S Hemalekha Justice K S Hemalekha pointed out that the body that manages film certification in India is commonly known as the Censor Board.

Kumar filed this claim against the director of the movie, Aditya Dhar and the producer, Jyoti Deshpande.

The Ranveer Singh-Sara Arjun starrer “Dhurandhar The Revenge” movie was released on March 19, and its first part was released on December 5, 2025.

Dhurandhar 2 based on ‘D Saheb’

The petitioner claimed to be a film writer, director and producer, who has authored an original script titled ‘D Saheb’ based on a patriotic theme involving anti-terror operations.

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It was contended that he developed the story, screenplay, character sketches and registered the same with the screen writers association and other authorities.

He claimed that, in 2023, he had shared the said script with various production houses and industry personnel, including Jyothi Deshpande, the producer of the film, through intermediaries who were engaged as a creative producer.

The petitioner added that the film director and writer, having gained access to his script, have unlawfully copied the same and produced the movie ‘Dhurandhar-2’, which was subsequently released in multiple languages across the nation.

Aggrieved by the alleged unauthorised use of his story and failure of the movie director and producer to give credit or compensation, the petitioner has approached this high court.

‘Matter of copyright law’

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  • The high court pointed out that whether Dhurandhar 2 is a plagiarised version of an original script is fundamentally a copyright law issue, not a matter for the film certification board.
  • The high court added that it constitutes a private proprietary rights dispute between the creator and the filmmakers.
  • The courts added that the petitioner has to prove that he is the rightful owner of the original script, that the filmmakers had access to the petitioner’s script, and that the movie is ‘substantially similar to the said script’.
  • The court emphasised that it should be proved by a full-fledged trial, which is to be handled through a civil suit.
  • The high court pointed out that the body that manages film certification in India is commonly known as the Censor Board.
  • It was further added that the Cinematograph Act, enacted by the Parliament, regulates the film exhibitions in India.
  • The legislation is designed to guarantee that films are appropriate for general viewing.
  • The high court added that it guarantees that they do not include any content that might offend or undermine public morals or decency.
  • The legislation also empowers the central government to set up a film certification body to evaluate and certify films for screening.

‘Vision of CBFC’

  • The high court pointed out that the vision of the CBFC is ‘to ensure good and healthy entertainment’ in accordance with the Cinematograph Act and the Cinematograph (Certification) Rules, 1983.
  • The high court further pointed out that the board certifies films, without which they are not allowed for public showing.
  • The Karnataka High Court clarified that the certification is a statutory authorisation, and once granted, the film can be exhibited subject to the conditions imposed.
  • The high court mentioned that the certification granted by the board is regarded as an ‘expert opinion, unless there is a blatant illegality’.
  • The high court added that the board is not a specialised forum for adjudicating private proprietary rights disputes or title over the script.
  • The court clarified that the challenge to certification by the petitioner is based solely on a private copyright dispute.
  • It was added that the same is not maintainable unless the petitioner can demonstrate ‘a manifest illegality’ in the board’s certification process.
  • The high court also mentioned that the petitioner can approach the civil court regarding a plagiarism claim.

‘Content of film illegal’

Appearing for the petitioner, advocate Rajesh K S argued that his client is the original author of the story, screenplay and concept of ‘D-Saheb’, which is duly registered and documented.

He further added that ‘Dhurandhar 2’ is a clear case of plagiarism, and the film-makers have unjustly enriched themselves by exploiting the petitioner’s private proprietary rights.

It was further added that the certificate granted by the CBFC under the Cinematograph Act, 1952, is liable to be interfered with, as the very content of the film is illegal and violative of the petitioner’s right.

It was also argued that the petitioner would suffer irreparable injury if immediate orders are not passed, as the film is being exhibited widely across theatres and OTT platforms.  

Richa Sahay is a Legal Correspondent for The Indian Express, where she focuses on simplifying the complexities of the Indian judicial system. A law postgraduate, she leverages her advanced legal education to bridge the gap between technical court rulings and public understanding, ensuring that readers stay informed about the rapidly evolving legal landscape. Expertise Advanced Legal Education: As a law postgraduate, Richa possesses the academic depth required to interpret intricate statutes and constitutional nuances. Her background allows her to provide more than just summaries; she offers context-driven analysis of how legal changes impact the average citizen. Specialized Beat: She operates at the intersection of law and public policy, focusing on: Judicial Updates: Providing timely reports on orders from the Supreme Court of India and various High Courts. Legal Simplification: Translating dense "legalese" into accessible, engaging narratives without sacrificing factual accuracy. Legislative Changes: Monitoring new bills, amendments, and regulatory shifts that shape Indian society. ... Read More

 

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