Orissa High Court Stays Release Of Animated Movie "Mahaprabhu Jagannath" On Plea Citing Depiction Distorting Spiritual History

The Court was hearing a Public Interest Litigation seeking a writ of mandamus directing the Central Board of Film Certification to revoke the certificate granted to the animated film and to restrain its public exhibition, screening and release within the State of Odisha, citing depiction of certain incidents which are opposed to the established religious traditions, the spiritual history and the practice prevalent since ages.

A Bench of Chief Justice Harish Tandon and Justice Murahari Sri Raman observed:

“While taking shelter under the freedom of expression and/or speech as guaranteed under Article 19 of the Constitution of India, a balance has to be created between such rights and the restrictions imposed under Article 19(2) of the Constitution of India. Even if the movie enjoins the guarantee of the freedom of expression and/or speech, but it impacted the thoughts and the action of the common people and, therefore should ensure high degree of attention and retention. At times it creates an immediate influence and at times may shatter the sentiments, the emotions and the religious belief, which cannot be allowed, if it results in unrest in the peaceful society. The motive to release the film may also be one of the facet to be borne in mind at a particular point of time, which may invite an immediate and prompt reaction having cascading effect, that would corrode the fabric resultantly affecting the peace in the society.”

Senior Advocate Manoj Kumar Mishra appeared for the petitioners, while Senior Advocate Gautam Mukherjee appeared for Ele Animations Pvt. Ltd.

Background

The petitioners approached the High Court alleging that the animated film “Mahaprabhu Jagannath” contained depictions contrary to established religious traditions, spiritual history and practices connected with Lord Jagannath.

The petition stated that the producer had published a teaser on YouTube announcing the film’s release. According to the petitioners, objections arose across Odisha, including from the Shree Jagannath Temple Administration, after which the film was screened before the Temple Administration and Gajapati Maharaja, Puri.

The petitioners alleged that several objections were raised during that screening and that the producer had assured necessary changes in line with well-established religious belief, tradition and cultural aspects. They further alleged that the producer later announced release of the film without making substantial or necessary changes in the narrative and animated depiction.

The petitioners objected to the alleged portrayal of fictional childhood or personal adventures of Lord Jagannath, the animated character speaking and behaving in an invented manner, and fictional battle or adventure sequences relating to Lord Jagannath.

The producer opposed the plea by submitting that the film carried a disclaimer that it was a fictional story and had no nexus with reality. It was contended that there was no attempt to destroy the belief of devotees, that Article 19(1)(a) protects freedom of expression and speech, and that the petition had been filed at the last stage despite considerable investment in the film.

Court’s Observations

The Court noted at the outset that the PIL sought directions against the release and screening of the film within Odisha, besides seeking revocation of the certificate granted by the Central Board of Film Certification.

The Court took note of the petitioners’ allegations that the teaser and content of the film had led to dissent regarding its title and depiction, including among persons associated with the Shree Jagannath Temple Administration.

The Court recorded: “It is highlighted in the instant Public Interest Litigation that on 06.06.2026 Ele Animations Pvt. Ltd. published the teaser in the You Tube channel announcing the release of an animated film titled “Mahaprabhu Jagannath” on 10 th July, 2026. Subsequently, there was a wide spread dissention on the title as well as the content of the said film across the people of the State of Odisha including the Shree Jagannath Temple Administration, which compelled the producer to exhibit the said film in the auditorium in presence of the Temple Administration as well as Gajapati Maharaja, Puri, where several objections were raised to the depiction of certain incidents which are opposed to the established religious traditions, the spiritual history and the practice prevalent since ages.”

The Bench also noted that the petitioners had highlighted objectionable portions of the film, including alleged fictional depictions involving Lord Jagannath.

The Court observed: “The petitioner has succinctly highlighted the objectionable portion of the said animated film, where the fictional childhood or the personal adventure of Lord Jagannath has been portrayed, which is not in tune with the religious texts of the Skandha Purana and the Brahma Purana. The animated actor playing the role of Lord Jagannath was also shown to be speaking and behaving in an invented manner, which are not in conformity with the devotional literature and the temple traditions and the cultures practiced and/or professed since the advent of the establishment of the Lord Jagannath Temple. The fictional battle and/or the adventural sequences relating to Lord Jagannath have also been included within the said picture, which not only tarnishes the belief of the devotees of Lord Jagannath, but also may invite a large scale of commotion amongst them.”

The Court also recorded the producer’s defence that the film was fictional, that it contained a disclaimer, and that it did not seek to affect the beliefs of devotees.

The Court stated: “On the other hand the producer arduously takes a stand that at the first screening of the animated film, there was a disclaimer that it is simply a fictional story having no nexus with the reality, nor is there any attempt made to destroy the belief of the devotees, and it would not corrode the fabric of the religious belief of the tradition, which the devotees perceive towards Lord Jagannath.”

The producer further relied on freedom of expression under Article 19(1)(a) and argued that every citizen is entitled to convey ideas and thoughts. It was also contended that the petitioners had approached the Court at the last stage to stop the release of the film.

The Court noted that a movie is one of the media through which thoughts, ideas and realities are expressed, but must be assessed by its overall impact on the public.

The Bench observed: “There are multiple mediums of expression of the thoughts, ideas and the realities of life viz. printed media, newspapers, printed articles, audio system and by releasing a movie to be screened in the theatre for the viewers. The moment it is expressed in the form of a movie, it has to be judged on the point of an overall impact on the public. Though they are primarily aiming for an amusement, but at times they create a massive impact in the minds of the viewers and/or the public, more particularly when it is intricately related to a religious belief and/or endowment as a devotee to the feet of God.”

The Court then considered the timing of the proposed release. It noted that the film was sought to be released when Rath Yatra was commencing and when a large congregation of devotees was expected.

The Court held: “The opposite party no.6 intended to release the said movie without bringing any change as suggested while screening the said film in presence of Gajapati Maharaja and the members of the Shree Jagannath Temple Administration when Rath Yatra (Car/Chariot Festival) is commencing from 16th July, 2026 where there will be a large conglomeration of the devotees at the spot and, therefore, we feel that screening of the said film on 17th July, 2026 shall be counterproductive. We have succinctly highlighted the objectionable content of the said animated film vividly and lucidly narrated in the instant public Interest Litigation, which needs to be determined in a threadbare manner after the exchange of the affidavits.”

Conclusion

The High Court restrained Ele Animations Pvt. Ltd. from releasing the animated film “Mahaprabhu Jagannath” on July 17, 2026 or thereafter without leave of the Court, or until the next date, whichever is earlier.

The Court directed the matter to be listed on August 5, 2026, along with the connected writ petition.

Cause Title: Mahesh Kumar Sahu and others v. State of Odisha and others

Appearances

Petitioners: Senior Advocate Manoj Kumar Mishra, with Advocate Sambit Kumar Patri

Respondents: Debasish Tripathy, AGA; Prasanna Kumar Parhi, Deputy Solicitor General of India, with Asutosh Mohanty, Central Government Counsel; Senior Advocate Gautam Mukherjee, with Advocates Sidhant Dwibedi and Supratik Acharya

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