- Why was Satluj removed from ZEE5? What do we know so far?
- Can the government legally order an OTT platform to remove a film?
- What legal safeguards apply before online content can be blocked?
- Can blocking orders remain confidential?
- Does the case signal a broader shift in the regulation of OTT platforms?
- What legal remedies are available to the filmmakers?
The story so far: ZEE5 removed the film Satluj from its OTT offerings soon after premiering it. While the filmmakers have said the government ordered the removal, reports have suggested that a Centre-appointed committee is examining the film under Section 69A of the Information Technology Act, though no official blocking order has been made public.
Why was Satluj removed from ZEE5? What do we know so far?
Satluj, directed by Honey Trehan and starring Diljit Dosanjh, premiered on ZEE5 on July 3 after years of delays over a certification dispute with the Central Board of Film Certification (CBFC). However, within two days, the platform removed the film from its India catalogue while continuing to stream it internationally through ZEE5 Global.
ZEE5 responded that the film has been removed citing “current developments”. In a statement shared on Instagram, the streaming platform wrote: “In light of the current developments, ‘Satluj’ will be unavailable in India until further notice. We remain committed to exploring every appropriate avenue through due process to bring the film back to our audiences at the earliest opportunity.”
The film’s OTT release came after years of controversy. Originally scheduled for a theatrical release in India, it hit roadblocks with CBFC. As per reports, the Board recommended a total of 127 cuts before granting the film certification. The delays ultimately forced the makers to postpone multiple release plans. Thus, it never made its theatrical release.
The film is set against the backdrop of Punjab during the insurgency years, through the life of activist Jaswant Singh Khalra. The film explores allegations of enforced disappearances, illegal detentions and extrajudicial killings during the State’s anti-insurgency operations in the 1980s and 1990s.
Can the government legally order an OTT platform to remove a film?
Unlike films released in cinemas, content released directly on streaming platforms does not require prior certification from the CBFC under the Cinematograph Act, 1952. Instead, OTT platforms are regulated under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
However, Section 69A of the Information Technology Act, 2000 empowers the Centre to block online content on limited grounds, including acts threatening the sovereignty and integrity of India, security of the State, defence of India, friendly relations with foreign States, and public order, or to prevent the commission of a cognisable offence. Any such blocking, however, must follow the procedure and safeguards prescribed under law.
What legal safeguards apply before online content can be blocked?
According to Apar Gupta, advocate and founder of the Internet Freedom Foundation, if the reported action against Satluj has been initiated under Section 69A read with the IT Rules, 2021, the government is expected to follow certain “procedure and safeguards”. Mr. Gupta explains that this includes a reasoned written order explaining how the content falls within one of the statutory grounds under Section 69A(1), an opportunity for the publisher to be heard, and review by the designated committee.
He points out that the Supreme Court, in Shreya Singhal v. Union of India (2015), upheld Section 69A because these procedural safeguards, including recorded reasons and an opportunity for hearing, formed part of the statutory framework. He notes that the constitutional validity of certain provisions of the IT Rules, 2021 remains under challenge before the Delhi High Court, invoking questions against the way government still uses these provisions.
Can blocking orders remain confidential?
One of the central questions is whether the government is required to disclose the reasons for a takedown. Rule 16 of the Blocking Rules contains a confidentiality provision. The government has increasingly relied on it to withhold blocking orders even from the affected parties. This undermines the rationale on which the Supreme Court upheld Section 69A in Shreya Singhal case since a blocking order that remains secret cannot be meaningfully challenged before the court of law.
Mr. Gupta points to the Delhi High Court’s decision in Tanul Thakur v. Union of India (2022), in which the court directed disclosure of the blocking order and a post-decisional hearing to the creator of a satirical website, recognising that confidentiality cannot be pleaded against the originator.
Without access to the blocking order, filmmakers cannot effectively challenge the decision, and the courts are left with little material to assess whether the restriction satisfies the constitutional test of proportionality laid down in decisions such as K.S. Puttaswamy v. Union of India (2017) and Anuradha Bhasin v. Union of India (2020).
Does the case signal a broader shift in the regulation of OTT platforms?
In practice, the executive blocking powers are increasingly being used to regulate online films after publication. There is a shift from pre-certification under the Cinematograph Act to post-publication executive control through Section 69A and the IT Rules. As OTT platforms fall outside the CBFC certification, the executive blocking powers risk functioning as a parallel censorship mechanism, one that lacks the transparency and statutory safeguards associated with film certification.
Mr. Gupta says, “Executive has repurposed Section 69A and Part III of the IT Rules, 2021 as a substitute censor Board, one without statutory standards, public hearings or appellate remedies.”
What legal remedies are available to the filmmakers?
If a blocking order has been issued, the filmmakers can challenge it before a High Court through a writ petition under Article 226 of the Constitution challenging the direction as ultra vires Section 69A and violative of Articles 19(1)(a) and 19(1)(g) of the Constitution, which provide the right to freedom of speech and expression and the right to practise any profession or carry on any occupation, trade or business, respectively.
According to Mr. Gupta, the Shreya Singhal case expressly preserved the availability of judicial review against blocking orders. He adds that the producers should also seek disclosure of the blocking order, participate in any proceedings before the Inter-Departmental Committee under protest, and pursue the review mechanism provided under the IT Rules.
Published – July 08, 2026 05:13 pm IST
