In a country like India where films and actors receive unparalleled public adulation, it is not surprising that the portrayal of women in cinema affects societal outlook. In this piece, Mrudula Dixit tells us how censorship by the Central Board under the Cinematographic Act of 1952 and court decisions have perpetuated problematic portrayals of women in films.

Before you dive into the article, here is a summary of the author’s analysis:

  • Stringent and misplaced censorship laws disproportionately affect representation of women in films. In her article titled ‘Visual Pleasure and Narrative Cinema’, Laura Mulvey has identified this ‘Male Gaze’ in cinema and concluded that movies are ‘gendered’. Women are objectified, subject to the criticism and pleasure of men.
  • Several possible solutions are available for solving this systemic problem. The Bechdel Test measures the representation of women in fiction. It states that a work of fiction, including films, should have two or more female characters (preferably named), who should talk to each other about something other than a man. This test may be used as a benchmark to foster women’s portrayal in the media. Moreover, Freud’s Madonna-Whore complex that embodies the dichotomy of a women’s identity (either a ‘virgin’ or a ‘whore’) in men's eyes should be recognized and demystified.
  • When it comes to Indian legislations, there is a lacuna in the Indecent Representation of Women (Prohibition) Act, 1986 with respect to the misrepresentation of women in an audio-visual form. The Cinematograph Act, 1952, also suffers from several infirmities; the Central Board of Film Certification is itself vulnerable to the Madonna-Whore bias and expurgates content accordingly. Thus, neither legislation actively works towards abandoning the ‘Male Gaze’ in cinema.
  • Lastly, the rise of ‘online cinema’ through OTT platforms such as Netflix, Amazon Prime and Hotstar also does not usher in the necessary reform. Online cinema lacks intersectionality and thus restricts the impact of ‘feminist media’ to the detriment of other marginalized groups like Dalit and Tribal women, queer and transgendered persons, and women with disabilities.
  • A reform in the current Cinematograph Act which limits the power of the Board is needed. The introduction of the Bechdel Test may also prove useful to correct misrepresentation.


Since independence, India has witnessed the suppression of creative freedom due to stringent censorship laws which disproportionately affect women’s representation. When women are depicted in mainstream cinema, their role is archaic, dismal, and derogatory. The portrayal of women in media is chiefly influenced by the Cinematograph Act, 1952, which in itself is fuelled by fierce protection of conservative ideals and mores, including the subordination of women in society. This becomes problematic due to the influence Bollywood has on Indians; the depiction of women in films has a direct causality to the way women are treated in society.

This short article attempts to navigate the reader through multiple layers of feminism (or the lack thereof) in cinema. I rely on Laura Mulvey’s Feminist Media Analysis to highlight the misrepresentation of women in films and critically discuss the role of the Cinematograph Act, 1952 and the jurisprudence evolved by courts and tribunals in perpetuating the problem.

Psycho-Analysis of Gendered Cinema

In 1975, Laura Mulvey, a British feminist film theorist, published her ground-breaking article titled ‘Visual Pleasure and Narrative Cinema’. The article was a psychoanalytic study demonstrating how the unconscious of the patriarchal society subliminally structured film form. According to her, women, because of their lack of a penis, signify a threat of castration. The ‘male look’ in the cinematic universe circles around this fact but never actually acknowledges it. Mulvey argued that men in films use two different methods to tackle the unpleasure embodied by women:

i)  To overcome the castration anxiety, women are portrayed as a mysterious and curious object, which the men seek to investigate or demystify (femme fatale); or

ii) When this fear is completely disavowed, the ‘dangerous’ entity (women) is converted into a fetish object so that she is reassuring rather than unsafe in the eyes of men.

Mulvey’s hypothesis is reflected in today’s ‘gendered’ films as well. Women are often portrayed as an object of the ‘male gaze’, subject to the criticism and pleasure of men.  If not the above, women in film are often illustrated as commodities through ‘item songs’ or other provocative scenes. Here, what counts in the film is what the heroine provokes and not what she signifies.

Violence against women is used to showcase the chivalry and strength of male counterparts, thus vastly trivializing the issue. In India, this problem is not limited to just physical or explicit violence, but rather, it is euphemized through ‘romantic comedies’ which reinforce the problematic notion of ‘chasing a girl’. A study conducted in 2002 noted that Bollywood movies in the 1990s depicted sexual harassment as ‘fun, enjoyable and a normal expression of romantic love’. A United Nations-sponsored study piloted by a leading California-based journalism school has shown that Indian films topped the chart in a sexualized portrayal of women onscreen. The issue of romanticizing sexual harassment is so deep-rooted that a court in Tasmania acquitted a man accused of stalking based on his defense that Bollywood films taught him that relentlessly pursuing women is the only way to woo them! However, there are several possible solutions to this systemic problem.

The Bechdel Test

The Bechdel-Wallace Test is a measure of representation of women in fiction. It states that a work of fiction, including films, should have two or more female characters (preferably named), who should talk to each other about something other than a man. Although this seems like an easy enough task, films often do not satisfy the test due to the inherent lack of women protagonists. It remains a common trope in Bollywood to center the women character(s) around a broader storyline of male aspirations. Apart from stereotypically male-oriented Bollywood mainstream cinema, even quotably ‘progressive’ female films manage to fail the Bechdel Test in India. For example, Veere Di Wedding is a film produced, co-directed by women, and starring four women as protagonists.While the women characters were named, they failed to talk about anything but relationships and men throughout the film, thus failing the Bechdel criteria.

However, the Bechdel Test suffers from certain infirmities. A woman’s conversation about something other than a man may serve the narrative arc of men, and sometimes a woman’s conversation about men can be feminist. For instance, a film that involves two women talking about being sexually harassed by men at work will fail the Bechdel Test, but a film where two characters briefly talk about clothes or shoes, but the entire storyline revolves around a man, will pass the Bechdel test. In such cases, the test can be complemented with other tests such as the Sphinx Test, which asks whether the woman is the ‘centre stage’ and whether she is active rather than merely reactive to a male character. Similarly, the Mako Mori test states that the female character should have an independent plot arc, and the development of her character should not depend on that of a man in the film. She should be able to make autonomous decisions about her goals. For instance, a film like Raazi (depicting a female intelligence agent) may fail the Bechdel Test but does have a strong female lead pursuing her own independent and ‘unconventional’ role.

The Madonna-Whore Complex

Freud’s Madonna-Whore complex, also known as the virgin-whore complex, embodies the dichotomy of women’s identity in the eyes of men. When a woman is ‘pure’, ‘virtuous’ and subservient, she is considered worthy of care but does not arouse any sexual desire in the man. On the other hand, a woman who enjoys her sexuality and maybe even uses it is considered fit for only sexual liberation but not for love or care. This dichotomy is present in cinema. Women are either ‘virgins’ or ‘whores’, but not both at once. For instance, the depiction of item songs is an ode to a woman's ‘whore’ identity while the girlfriend, wife, or potential love interest embodies the Madonna identity.

The Cinematograph Act’s Flaws

The only body in India with the unfettered power to review films and cinematic literature is the Central Board of Film Certification (CBFC’ or ‘Board’) formed under the Cinematograph Act of 1952 (‘Act’). Since its inception, the CBFC has refused certification or censored cinema on grounds varying from excessive violence, crudity, indecency, and morality. Under the Act, guidelines have been issued which prevent the release of a film offending human sensibilities by vulgarity, depravity, and obscenity, by degrading, or denigrating women in any manner or by broadcasting scenes of sexual violence not germane to the theme of the film.

However, the Board has been under fire for rampant censorship based on a skewed sense of ‘morality’. With 25 individuals (mostly male), the Board should have no authority to stifle new ideas and expurgate content from cinema. With its flawed interpretation of ‘decency and morality’ rooted in a patriarchal conception of society, the Board cannot be said to reflect the nation's spirit, nor does it safeguard creativity and innovation.  Due to the CBFC, films like Fire, and Gulabi Aaina, which touch upon subjects concerning the LGBTQ+ community, have been ‘banned’ in India. In April 2017, CBFC refused to certify the Hindi drama Lipstick under my Burkha. The film revolves around the lives of four women, all engaged in ‘unladylike’ behavior. What is unique about the film is that the female characters are central while the men carry out supporting roles. Alankrita Srivastava, the director, tried to emphasize the ‘female gaze’ by subjecting men to women’s active voyeurism . However, the CBFC reasoned that the story was ‘lady-oriented, their fantasy above life’ and contained continuous sexual scenes and abusive language. This refusal to certify was subsequently challenged before the Film Certification Appellate Board (FCAT), and the movie was released with an ‘A’ (Adult) Certificate.

Even Courts have been reluctant to rectify women’s representation in cinema. In 1988, Pati Parmeshwar was deniedcertification by CBFC. The movie concerned the life of a wife who was ready to sacrifice her desires and wants for her husband's whims and wishes. At the time, the CBFC's guidelines prohibited the exhibition of films that contained visuals or words depicting women in ‘ignoble servility to man’ or glorified such servility as a praiseworthy quality in women. The CBFC’s reliance on these guidelines to deny certification was challenged in the Bombay High Court. Justice Lentin stated that the manner in which the wife’s servility is depicted and glorified in the film was not in accordance with the standard of decency, as commonly understood and recognized. It was indecent to the point of repugnancy. The wife’s servility was further glorified when she took her husband to a ‘mistress’. However, the two remaining judges held that the wife’s character is one of faith, dedication and endurance and not of servility. According to them, she was not servile, but on the contrary, was ‘committed to her husband and went all out to save her marriage’; such behavior was in line with the Indian culture of marriage.

These case-studies of Pati Parmeshwar and Lipstick under my Burkha highlight the predominance of the Madonna-Whore complex discussed above. In the former, the husband is ‘attracted’ sexually to a prostitute but relies on his wife for emotional support and well-being. This strengthens the dichotomy that a man dislikes a sexually autonomous woman but is still attracted physically to her. On the other hand, a conventional submissive woman who heeds the man's wishes is nothing but a caretaker and too ‘pure’ for sexual attraction. When the latter film tried to inverse this complex by subjecting men to the ‘female gaze’, it received legal backlash, a dismal but unsurprising portrayal of the CBFC’s understanding of morality.

The CBFC itself suffers from this complex due to its own two-pronged and contrasting views on the ‘correct’ identity of a woman. The CBFC considers itself the protector of women’s morality by fashioning every woman into a Madonna. However, when it comes to representation of ‘whores’ in common cinema, the CBFC is reluctant, as such women do not conform to their notion of a pure woman.

As things currently stand today, a petition has been filed by director Amol Palekar to the Supreme Court, which questions the powers of the CBFC as well as the Ministry of Information and Broadcasting to pre-censor content, but no judgment has been delivered.

A Gaping Void in Law and the Lack of Intersectionality

When it comes to reforming the current landscape, little can be done unless the Act is substantially modified. This is due to two reasons. First, there is a lack of legislation to tackle the misrepresentation of women in audio-visual form. The Indecent Representation of Women (Prohibition) Act, 1986 is one of the few statutes in our country that addresses the issue of obscenity specially directed towards women. However, the law is limited to print media like flyers, posters, and magazines.

Second, online cinema, which is not subject to the CBFC guidelines, has also failed to rectify women’s representation in cinema. Although online content broadcasters like Netflix India, Prime Video, and Hotstar offer a wide variety of content which is excluded from the scrutiny of the CBFC due to its non-linear form, a major issue identified with respect to most of them, especially those curated for an Indian audience, is the lack of intersectional feminism. Amazon Prime and Netflix originals Lust Stories and Four More Shots Please as well as the YouTube series Trip propounds a narrow, privileged view of feminism. Though it passes substantially all checkpoints of a ‘feminist’ media, it limits itself to the problems of the economically well-off, educated, and urban Indian women. This, in turn, restricts the impact of feminism to the detriment of other marginalized groups like Dalit and Tribal women, queer and transgendered persons, and women with disabilities. This depiction of women in cinema, as a ‘revolt’ against the traditional approach, is limited to women engaging in vices that only men previously enjoyed, such as smoking, drinking, or delving in adultery.  Though these acts are not disputed on grounds of gender, they do not address the issue of patriarchy in cinema. Thus, unfortunately, even in the absence of CBFC scrutiny, there still remains a dearth of films which tackle the concerns of marginalized women.


Perhaps, for certification, the CBFC should incorporate the Bechdel Test for films. This has already been done by four cinemas in Sweden as well as a few Scandinavian TV channels, and the Swedish Film Institute supported this move. Another approach can be a radical reform of the Cinematograph Act, 1952. This was proposed in 2018 when Shashi Tharoor introduced the Cinematograph (Amendment) Bill, 2018 in the Lok Sabha. According to him, the Bill sought to remove the pre-censorship powers of the CBFC, restrict the ability of the Government to censor films, respect artistic freedom and lastly, retract the power of the Government to overrule the decisions of the CBFC. Although such a Bill may not attain the level of reform desired for women’s representation in the media, it will be a step in the right direction. However, women’s fair representation in cinema can be positively achieved only through an active approach; by active production and release of films focusing on women and the LGBTQ+ community and through the systematic unlearning of an ideal women’s ‘morality’.

This article is an abridged version of the author’s full-length research paper published in the Delhi Law Review Student Edition (Vol. VII). To access the paper, please click here.