IN THE SUPREME COURT OF INDIA

(CIVIL ORIGINAL JURISDICTION)

WRIT PETITION (CIVIL) NO, 877_OF 2022
(WITH PRAYER FOR INTERIM RELIEF)

IN THE MATTER OF:

Shri Chitragupta Welfare Trust Petitioner

Versus

Central Board of Film Certification& Ors. .. Respondents

WITH
LA. NoSO0 21 2022 Application for ad-interim ex-parte stay.

PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)

ADVOCATE FOR THE LOKESH KUMAR CHOUDHARY

PETITIONER
O N
 INDEX

PAGE NO. OF PART REMARKKS

TO WHICH IT
BELONGS
SL. PARTICULARS OF
NO. Part
DOCUMENT (Contents
Part II
(Contents
of Paper of File
Book) Alone)
) (i) (ii) (iv) (V)
1.
Listing Proforma. A1 A2 A1 A2
2. Cover Page of Paper Book A-3
3 Index of Record of A-4
proceedings
4 Defect List A-6

5 Note Sheet NS-1

6. Synopsis, List of Dates &
Events. B D
7. Writ Petition under Article 32
of Constitution of India, with
supporting Affidavit.
1- 13

8 Annexure P-1: Copy of

Authorization Letter.

9. Annexure P-2 Copy of JS-16|

detail containing characters
in the movie.

10. Annexure P-3: Copy of 720

Note/ Summary on God
Chandragupta.

11. Annexure P-4: Copy of2-1-23

posters of the movie.
12. Annexure P-5: Copy
email dated 20.9.2022.
of 2

13. I.A. No. j2022:2S-2|

Application for Stay.

14. Filing Memo. 28

15. VIA
 A
ANNEXURE X
PROFORMAFORFIRST LISTING
SECTION:. **********°°°°***°

The case pertains to (Please tick/ check the correct box):

Central Act: (Title): Constitution
of India.
Section: Articles 14 & 25. Also Section 5B of
Cinematograph Act.
OCentral Rule: (Title): -NA-
Rule No(s): -NA

State Act: (Title): -NA-

Section: -NA-
O State Rule: (Title): -NA-
Rule No(s): -NA-
Impugned Interim Order: (Date):-NA-
Impugned Final Order/Decree (Date):-NA-

High Court (Name): -NA

Names of Judges: -NA-
Tribunal/ Authority: (Name):-NA

1. Nature of Matter: Civil Criminal

2. (a) Petitioner / Appellant No. 1: Shri Chitragupta Welfare Trust.

(b) e-mail ID: -NA-

(c) Mobile phone number: 7289867495.

3. (a) Respondent No.1: Central Board of Film Certification &Ors

(b) e-mail ID: -NA-

(c) Mobile phone number: -NA

4. (a) Main categoryclassification: 27 Rl gious chastable endwment

(b) Sub Classification: 2t03 0rS

5. Not to be listed before:-NA

 A1
6. (a) Similar disposed of matter with citation, if any & case details: -Nb Similan Matn
diposte of.
(b) Similar pending matter with case details: -No- Smla Malli Pondmm

7. Criminal Matter: No.

(a) Whether accused/convict has surrendered: Yes No

(b) Fir No.: -NA- Date:-NA
(c) Police State: -NA-

(d) Sentence Awarded:-NA-

(e) Period of sentence undergone including period of detention/custody
undergone: -NA-

8 Land Acquisition Matters:-NA-

(a) Date of Section 4 notification: -NA-

(b) Date of Section 6 notification:-NA

(c) Date of Section 17 notification: -NA

9. Tax Matters: State the tax effect:-NA-

10. Special Category (first petitioner/ appellant only):-NA-

Senior citizen > 65 years SC/STOWoman/ child Disabled

Legal Aid Case In custody.
of Motor Accident Claim
11. Vehicle Number (in case
Matters): -NA

Date: 2.9. 2o2 (LOKESH KUMAR CHOUDHARY)

AOR FOR PETITIONER
REGISTRATION NO..
 SYNOPSIS, LIST OF DATES & EVENTS

The present Petition arises out of and against derogatory expressions,

acts, statements, dialogues and insulting images, videos in and around

the character of God Chitragupta played by Bollywood Actor, Ajay

Devgan, which is evident from the release of trailer of Bollywood movie

"Thank God" (hereinafter referred to as "the said Movie/Film") and

is in violation of Section 5B of the Cinematograph Act, 1952 as well as

Articles 14 and 25 of the Constitution of India. The Respondent

No.2/Indra Kumar is the Director and Respondent No.3/Bhushan

Kumar, along with various other Producers, is the Producer of the said

movie. Moreover, Respondent No.1 being the Central Board of Film

Certification (CBFC), who works under the Respondent No.5/Ministry

of Information a6nd Broadcasting, Govt. of India, has certified the said

movie and has given clearance for release thereof in theatres/cinemas

25.10.2022, apart from release on OTT

halls across the country on

platform etc.. The fact that the Respondent No.1 ought not to have

clearance and certification for release of the

said movie, which
given
acts, gesture, talks etc.
contains various objectionable and derogatory

behest of God Chitragupta, which are not

totally against and on

in the country and Hindus or

acceptable at all for Kayastha community
Needles to state that the said
God Chitraputa is followed
otherwise.
 C
and worshiped by Kayastha community in India and Hindus, which

includes Srivastava, Saxena etc.

It is respectfully submitted that the release of the said movie in

theatres/cinema halls all over India and/or on OTT platform would not

only harm and cause injury to sentiment of the Petitioner, but also

crores of people of Kayastha community and Hindus and could cause

chaos and thus, peace and harmony in the country could be disturbed.

As such, there is utter violation of Articles 14 and 25 of the Constitution

of India, apart from Section 5B of Cinematograph Act, 1962. Thus,

the release of the said movie is liable to be stayed permanently and

the Respondents are liable to be penalized as per law.

3d
week The Petitioner came to know about the movie and
of Sept,
watched trailer of the said movie available on YouTube,
2022

Google etc.

Petitioner wrote emails to Respondents, requesting them

2.9.2022
not to release such trailer of
the said movie and movie

was received from the

itself, but no response

date for release of the said

Respondents. Moreover, the
India as well as on OTT platform
movie in theatres all over

25.10.2022.
is fixed for
 Aggrieved by the
D
already released trailer and further
release of the said movie, which
contains various
objectionable and derogatony acts, gesture, talks etc.
totally against and on behest of God Chitragupta, apart
from acts of omission and
commission on the part of
Respondents, Petitioner is left with no other option, but to
approach this Hon'ble Court
by way of the present
Petition

229.2022 Hence, the present Writ Petition.

 IN THE SUPREME CcoURT OF INDIA
(CIVIL ORIGINAL JURISDICTION)

WRIT PETITION (CIVIL) No._877oF 2022

IN THE MATTER OF:

Shri Chitragupta Welfare Trust

Having its office at
3, West Guru Angad Nagar
Laxmi Nagar
New Delhi-110092
Through its Trustee & Authorized Signatory
Smt. Deepmala Srivastava ..Petitioner

Versus

1. Central Board of Film Certification (CBFC)

Films Division Complex
Phase-l Building, 9h Floor
Dr. G. Deshmukh Marg
Mumbai-400026
Through its Chairman

2 Shri Indra Kumar, Director

Maruti International Studio Pvt. Ltd.
32, Rock Garden
Link Road,
Andheri
Mumbai-400053

3 Shri Bhushan Kumar, Producer

Super Cassettes Industries Pvt. Ltd.
E-2/16, Ansari Road

Daryaganj
New Delhi-110002

Actor
4. Shri Ajay Devgan,
5/6, Sheetal Apartments
Chandan Cinema
Ground Floor, Opp.
Juhu
Mumbai
 5. Ministry of Information & Broadcasting
2
Government of India
Room No.552, 'A" Wing
Shashtri Bhawan
New Delhi-110001
Through its Joint Secretary ...Respondents

PETITION UNDER ARTICLE 32 OF THE cONSTITUTION OF INDIA

FOR ISSUANCE OFA WRITIN THE NATURE OF MANDAMUS AND
PROHIBITORY AGAINST RESPONDENTS FOR DEROGATORY
EXPRESSIONS, ACTS, STATEMENTS, DIALOGUES AND INSULTING
IMAGES,VIDEOS IN AND AROUND THE CHARACTER PLAYED ON
BEHEST OF GOD CHITRAGUPTA BY BOLLYWOOD ACTOR, AJAY
DEVGAN, IN UPCOMING BOLLOYWOOD MOVIE "THANK GOD"
WHICH ARE UNCONSTITUTIONAL ACTS ON THE PART OF
RESPONDENTS AND IN UTTER VIOLATION OF FUNDAMENTAL
RIGHT OF THE PETITIONER ENSHRINED UNDER ARTICLES 14,
25OF THE CONSTITUTION OF INDIA AS WELL AS SECTION 5B
OF CINEMATOGRAPH ACT, 1952.

To,

The Hon'ble Chief Justice of India and His Hon'ble Companion

Justices of the Hon'ble Supreme Court of India.

The humble Petition of the Petitioner above named.

MOST RESPECTFULLY SHOWETH:

1 The present Petition arises out of and against derogatory

expressions, acts, statements, dialogues and insulting images,

videos in and around the character of God Chitragupta played by

 3
Bllywood Actor, Ajay Devgan/Respondent No.4, which is
evident from the release of trailer of Bollywood movie "Thank

God" (hereinafter referred to as "the said Movie/Film") as is

evident from already released trailer of the said movie. Thus,

the release of the said movie will in utter violation of Articles 14

and 25 of the Constitution of India, and also Section 5B of

Cinematograph Act, 1952. Respondent No.1 is the censor

board, who certifies the bollywood movies to be released. The

Respondent No.2/Indra Kumar is the Director and Respondent

No.3/Bhushan Kumar, along with various other Producers, is the

Producer of the said movie, whereas, Respondent No.4/Ajay

Devgan is the lead actor in the movie. Respondent No.5 is the

Ministry of Information and Broadcasting. The Petitioner is a

Trust in the name of God Chitragupta, which is being

represented by one of its Trustee, Smt. Deepmala Srivasatava.

Copies of Authorization Letter in favour of Smt. Deepmala

Srivastava and details of note containing names of Actors,

Director, Producers etc. of the said movie are annexed hereto

and marked as Annexure P-1 (Page 4 t o 9 ) and

Annexure P-2 (Page Sto b).

1(a). That the Petitioner has not filed any similar or other petition

either before this Hon'ble Court or any other court against the

Respondents seeking similar relief/s

 Petitioner learnt
That in the 3" week of September, 2022, the
movie on YouTube
about the release of the trailer of the said
the Petitioner
and other electronic platform and subsequently,
movie. Moreover, God
watched the trailer of the said

of devotees,
Chitragupta is followed and worshiped by
crores

in the country
especially the people of Kayastha Community
about
since past many centuries. Copy of brief note/summary

annexed hereto and marked as Annexure P-

God Chitragupta is

3 (Pages to 20)

That apart from already released audio video trailer of the said

been released, which

movie, various types of posters have also

are also spreading wrong, insulting and derogatory messages

among the people across the country

against God Chitragupta
well. Copy of some posters of the movie is
and in the World, as

annexed hereto and marked as Annexure P-4 (Pages 21 to

A. That on 20.9.2022, Petitioner wrote emails to the Respondents,

release the said movie, containing

requesting them not to

various derogatory and insulting acts, dialogues and things

which is evident from the trailer of

against the God Chitragupta,
dated 20.9.2022 written to
the movie released. Copy of email/s
 Respondents by the Petitioner are annexed hereto and marked

as Annexure P-5 (Pages 2 to

A. QUESTIONS OF LAW:

(A) Whether the Respondent No.1 has erred in certifying and

ermitting the release of the said movie, namely "Thank

God" containing derogatory acts, dialogues, expressions,

acts, statements, and insulting images, videos of God

Chitragupta played by Bollywood Actor, Ajay

Devgan/Respondent No.4?

B) Whether release of said movie would be in violation of

Articles 14 and 25 of the Constitution of India, and also

Section 5B of Cinematograph Act, 1952?

(C) Whether religious sentiment of the Petitioner, including

other Kayastha people in the country and Hindus is not

being harmed/ injured upon acting against and on behest

of God Chitragupta in the said movie, containingg

objectionable, derogatory and insulting acts, expression,

statements etc.?

Whether fundamental right of the Petitioner is not infringed

(D)
and violated by the Respondents by making and releasing

such movie, i.e. Thank God?

 6
and/or authority
have any right
Whether the Respondents
(E)
means,
who is
various
to insult God Chitragupta
by
India and
crores of people in
followed and worshiped by
community?
the World, belonging to Kayastha

in causing
would not result
Whether release of said movie
(F)
harmony in the
disturbance of peace and
chaos and

by the Kayasth
agitation/procession
country upon

said movie?
Community against the

to have denied of
Whether the Actor, Ajay Devgan ought
(G)
which is not justifiable
playing the role of God Chitragupta,

manner?
legally as well as religiously, in any

GROUNDs

Petition under Article 32 of the

The Petitioner prefers the present
issuance of writ in the nature of
Constitution of India for

on the following, amongst

Mandamus against the Respondents,
her fundamental right as
other, grounds to protect and safeguard

the Constitution of India,

under Articles 14 and 25 of
enshrined

Act, 1952.:
Section 5B of Cinematograph
and also under
 GROUNDS

Because the Respondent No.1 has erred in certifying and

A
permitting the release of the said movie, namely "Thank

God" containing derogatory expressions, acts, statements,

dialogues and insulting images, videos of God Chitragupta and

played by Bollywood Actor, Ajay Devgan.

B Because the trailer of the movie already released and

movie to be released across the country on 25.10.2022

will be in utter violations of Articles 14 and 25 of the

Constitution of India, and also Section 5B of

Cinematograph Act, 1952.

C. Because the religious sentiment of the Petitioner, including

other Kayastha people in the country is being harmed/

injured and fundamental right is infringed and violated by

the Respondents by making and releasing the said movie.

D Because the Respondents cannot have any right and/or

authority to insult God Chitragupta, who is followed and

worshiped by crores of people in India and the World,

belonging to Kayastha community.

Because the release of said movie would result in causing

E
chaos and disturbance of peace and harmony in the
 country upon agitation/procession by the Kayasth

Community across the country.

F Because the Actor, Ajay Devgan ought to have denied the

role/character of God Chitragupta, which is not justifiable

and acceptable legally as well in the
as religiously country.

G Because various posters of the movie, apart from the

visual trailer of the movie, have been released across the

country, including online platforms and thus, wrong, illegal

and anti-religious messages are being spread.

H. Because the fundamental right of the Petitioner cannot

be

infringed and/or trespassed by the Respondents, as has

been done by making the said movie.

Because no response was given by the Respondents to

her emails written to them, requesting them to remove the
trailer already released, from YouTube and other
online/offline platforms and further not to release the said

movie, "Thank God".

J. Because the Respondents have failed to take

any
appropriate steps for removal of trailer of the said
movie
from YouTube or otherwise.
 q-10

Because the Respondents are liable to be punished for

K.
K.

violation of Articles 14 and

25 of the Constitution
acting in

of India and for violation of Section 5B of Cinematograph

sentiment of the
Act and for causing injury to the religious

Petitioner towards God Chitragupta.

L Because even otherwise, the acts of Respondents against

the God in the said movie are derogatory and

Chitragupta

insulting, which are not acceptable at all.

6 That the present petitioner has not filed any other petition in any

High Court or the Supreme Court of India on the subject matter

of the present petition.

7 That the Petitioner craves leave of this Hon'ble Court to alter and

amend any grounds mentioned above, if so required.

8. That the Annexures/documents filed with the present Petition are

true copies of their respective originals.

9. PRAYER

In the facts and circumstances mentioned

above, it is, therefore,
most humbly and respectfully prayed that this Hon'ble Court
may
be pleased to: -
 (a) Issue writ in the nature of mandamus and prohibitory,

to
against the Respondents, directing the Respondents

remove trailer and posters of the said movie from the

YouTube and other electronic platform forthwith and

further not to release the said movie, namely "Thank God"

containinng derogatory expressions, acts, statements,

dialogues and insulting images, videos of God Chitragupta

and

(b) Issue writ in the nature of mandamus and prohitbitory,

directing the Respondents to ensure that trailer will be

removed from all forms of platform, including YouTube etc.

and further the said movie is not released in

theatres/cinema halls across the country or on OTT

platform; and/or

(c) Pass such other or further order or orders or such

directions as this Hon'ble Court may deem fit and proper

in the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY

BOUND SHALL EVER PRAY.

DRAWN & DRAFTED BY: FILED BY:

(MOHAN LAL SHARMA) (LOKESH KUMAR CHOUDHARY)

ADVOCATE FOR THE PETITIONER
ADVOCATE
FILED ON: 22 9 20 2
 INDIA
IN THE SUPREME COURT OF
(CIVIL ORIGINAL JURISDICTION)

WRIT PETITION (CIVIL) NO. 77OF 2022

IN THE MATTER OF:

.Petitioner
Shri Chitragupta Welfare Trust

Versus

Central Board of Film Certification & Ors. .. Respondents

AFFIDAVIT

Srivastava W/o Shri Lokesh Kumar Shrivastava,

R/o 1-62,
I, Deepmala
First Floor, Sector-27, Noida-201301, presently at New Delhi, do hereby

solemnly affirm and declare as under:-

1. That I am one of the Trustees and Authorized Signatory of the

and well
Petitioner Trust in the abovementioned matter
am

conversant with the facts of the case and as such, am competent

and authorized to swear this Affidavit.

OA
2
2Thathave read and understood the conterts. 9fthe
áccompanying Synopsis, List of Dates & Events,{Petitionent
y
TA's beèn drafted under
Applicationts) and state that theeemebave
.

8.L.
NO
oTARP .

K. BANDANA
D4lhi
Regd. ya 19718
Date pf Epiry

oVT. 26.02.2025

OFV
 h

my instructions. Facts stated therein are true and correct to my

knowledge and belief.

3. That the annexures filed along with Special Leave Petition are

true copies of their respective originals.

A That the Writ-Retition has

OTA
been.drafted 19.9.2022 consistingat-
on

Page A
PageBto 03 Pages) in the Synopsis, Listgf DatesNA\
and
B.ADANA Dai 9718
Events, and Raras 1 tó \lo_(from Pages Oto20 11*) in
Regd. M. 97
the Writ26.02.
Petition"
***

/DEPONENT
IDNlFiED
VERIFICATION
the21 SEP 2822
Verified at New Delhi on this the2 day of September, 2022 that
statements of facts stated in the foregoing
paragraphs of the affidavit
are true and correct to my knowledge. Nothing is false and no material
fact has been concealed therefrom.

oTAR 2 S E P 2 8 2 2

n r o zhRE
N DEPONENT
K. BANDANA
Delhi/
Regd. NoA9718
Date Of Eypiny

OVTSOvT. 26.02.2025

ATFSTED
NOTARY PHBLIC DELHI
GOVT. OÉ INDIA
Mob.: 9654768498
 AnMExVRE P-I

PTA CHITRAGUPTA WELFARE

TRUST
SHRI Delhi- 110092
Laxmi Nagar,
Add. 3, WestGuru Angad Nagar, faretrust@gmail.com
E-mail: shrichitraguptawel
Landline No., -011-49071804, Mob. 9311979445,

Authority Letter
Date: 17 September 2022

We authorized Ms. Deepmala Srivastava (Trustee) to take any legal action against the Bollywood

Film "Thank GOD'".

$hrNaYtoN
1. Lokesh Kumar Shrivastava LokeSn Trusi
Welfare
M/s Shri Chitragupta

2. Deepmala Srivastava
Trustee
M/s Shri Chitragupta Welfare Trust
3. Anupam Srivastava
brdumvas Fa/G
Trustee

Tnu coPy)
 ANNExUR E P-2

Cast

Ajay Devgn as Chitraguptale

Sidharth Malhotra as Aayan Kapoor
Rakul Preet Singh as Ruhi Kapoor
>Kiku Sharda as Aayan's colleague
Seema Pahwa as Aayan's mother
Urmilla Kothare as Aayan's sister
>Sumit Gulati
Nora Fatehi special appearance in the song "Manike"

Directed by Indra Kumar

Written by Aakash Kaushik

Madhur Sharma
Produced by Bhushan Kumar
Krishan Kumar
Ashok Thakeria
Sunir Kheterpal
Deepak Mukut
Anand Pandit
Markand Adhikari

Starringg Ajay Devgn

Sidharth Malhotra
Rakul Preet Singh
Cinematography Aseem Bajaj
Dharmendra Sharma
Edited by
Music by Score:
Amar Mohile
Songs:
Tanishk Bagchi
Rochak Kohli
Anand Raaj Anand
Chamath Sangeeth
Production T-Series Films
Maruti International
companies
Soham Rockstar
Anand Pandit Motion Pictures

Distributed by AA Films

Release date 25 October 2022

Country India
Language Hindi

nucoPy
 ANNEXURE P-3

task of keeping complete

hitragupta is Hindu deity assigned with the
a
or rewarding them
records of the actions of human beings and punishing
has the task of
according to their karma. Upon their death, Chitragupta
aeciding whether humans to Svarga or Naraka
go
(heaven or hel)
the seventeenth
aepending on their actions on earth. Chitragupta is
from
ianasaputra of Brahma. He is believed to have been created
right to write Vedas
Brahma's soul and mind (chit) and thus is allotted the
ike a Brahmin, and also assigned the duty of a Kshatriya. Chitragupta

accompanies Yama, the god of death.

referred to as
A large central panel portrays Yama the god of death (often
demon. To the right of
Dharma) seated on a throne; to the left stands a

Yama sits Chitragupta, assigned with keeping detailed records of every

human being and upon their death deciding how they are to be reincarnated,
depending on their previous actions.

The Yama Samhita, an extract from the 9th chapter of Ahilya

Kamdhenu, a work of Hindu Law, says that Dharamaraja complained
to Brahma about his difficulties in performing his most responsible
duties of keeping records of the deeds of men and doing justice to

them. Brahma went into meditation. Chitragupta sprang from his body
and stood before him bearing an inkpot and a pen. The god Brahma
(creator) said: "Because you are sprung from my body (kaya),
therefore you shall be called Kayastha and as you existed in my body
unseen I give you the name of Chitragupta. Let the Kshatriya dharma

be followed by you and your progeny." He then assumed charge of

Yamapuri. Yama setup marriage of his daughter Iravati with

of Lord Surya, setup his
Chitragupta. Sraddhadeva Manu, son

daughter Nandini's marriage with Chitragupta. Chitragupta had eight

sons from the former and four from the latter and these twelve sons

the progenitors of the twelve subdivisions of the

became
Chitraguptavansi Kayasthas, namely Saxena, Mathur, Gaur, Nigam,
 Bhatnagar, Ambastha,
Ashthana, Kulshrestha, Suryadwaja,

Shrivastava, Karna and Vaalmik.

near Yama to
ACCording to Padma Purana, "Chitragupta was placed
register the good and evil actions of all sentient
beings, that he was
of
possessed of supernatural wisdom and
became the partaker
reason that the
sacrifices offered to the gods and fire. It is for this

TWice-born always give him oblations from their

food. As he sprang
from the body of Brahma he was called Kayastha of numerous gotras

on the face of the earth."

name and
Bhavishya Purana states that God, the Creator, gave the
duties of Chitragupta as follows: Because you have sprung from my
be famous in
body, therefore, you shall be called Kayastha and shall
the world by the name of Chitragupta. Oh my son, let your residence
be always in the region of the God of justice for the purpose of

determining the merits and demerits of men.

Vignana Tantra evokes the same verses as the Bhavishya Purana.

The same is the enjoinment of Brahma to Chitragupta according to

Brihat Brahma Khanda. He was named Kayastha having sprung from
the body (kaya) of Brahma. He was directed to perform all sanskars
and to have writing as his profession.
Garuda Purana describes the imperial throne of Chitragupta in
Yamaloka holding his Court and dispensing justice according to the
deeds of men and maintaining their record, in the following words:
(There Dharmaraja, Chitragupta, Sravana and others see all sins and
virtues remaining concealed in the bodies of men).

The Mahabharata (Anusasana Parva, chapter 130) recites the

teaching of Chitragupta requiring men to do vituous and charitable

acts and performing Yagya, saying that men are rewarded or

bad deeds.
punished according to their good
or
Legends
r a g u p t a came into being after Brahma, the creator, having estabilisnea

ne Tour varnas Brahmin (The Learned), Kshatriya (The warriors),

Vaishya (Merchant & Farmers) and Shudra (Labourer) ordained Yama

Keep record of the d e e d s - good and e v i l - of all life-forms born and yet to

be born on earth, in the heavens above and in the lands below. Yama,
however, complained, "O Lord, how can I alone keep record of the deeds of

the beings born into 84 lakh yonis (84,00,000life-forms) in the threeworids

In the Garuda Purana, Chitragupta is hailed as the "giver of letters

(Chitragupta namastubhyam vedaksaradatre).

In the legends of Chitragupta as well as in the Vedas, he is referred to as the
greatest king, while the rest are "Rajakas" or little kings.

The Rig Veda mentions an invocation to be made to Chitragupta before

offering sacrifice. There is also a special invocation to Chitragupta as
Dharmraj (Lord of Justice) to be made at the performance of shradh or other
rituals. "Om tat purushaya vidmahe Chitragupta dhimahi tena lekha
prachodayata."

Chitragupta is said to have been born in humanform at Kayatha in Ujain,

which is also an important archeological site with evidence of cultures dating

back to more than 4000 years, with a temple dedicated to him.

Chitragupta is the Athi Devathai for Ketu, one of the Navagrahas, and those

who worship Chitragupta, would be bestowed with prosperity. Also the evil
be mitigated.
effects of Ketu during its transit period would

Temples

There are numerous temples dedicated to Chitragupta. Notable examples

include:
 20
Pradesh
Chitragupta temple, Khajuraho, Madhya is

g u p t a temple, Kayatha, Ujain,

Madhya Pradesh - Chitragupta
whicn is
in Ujain,
said to have been born in humanform at Kayatha
evidence of cultures dating
aiso an important archeological site with
to him
N LOmore than 4000 years, with a temple dedicated

Chitragupta temple, Kanchipuram

There are numerous temples dedicated to Chitragupta. Notable examples

include:

Chitragupta temple, Khajuraho, Madhya Pradesh

is
Chitragupta temple, Kayatha, Ujain, Madhya Pradesh Chitragupta
said to have been born in humanform at Kayatha in Ujain, which is

also an important archeological site with evidence of cultures dating

back to more than 4000 years, with a temple dedicated to him.

Chitragupta temple, Kanchipuram, Tamil Nadu - the oldest temple in

South India dedicated to Chitragupta. Archaeologist have confirmed

based on the inscriptions that the temple was built during the 9th

century by the Medieval Cholas.

.Chitragupta Devalayam, Falaknuma, Hyderabad built by Kayasthas
employed by the Qutb Shahi's in early 18th century

(T copy)
 yk E P- y
ANNEx

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GULSHAN KUMAR, T-SERIES

MARUTI NTERNATIONAL PHESEN
s

MAN A-SERIES FRMS6MARUTI NTERNATIORAL PROCctON

THANK
EOD DRA KUMAB

TRAILER ON
9TH SEPT. PaOUCES 8T BKUSHAN KUMAR.KRESHAN KUMAR
ROOUCED ET ASHOK THAKERIA, SONIR KMETERPAL OEEPAx MUKUT
PROOCEEY INDRA KUMAR, ANANO PANDIT,MARKARO ADHIKAR

4[AJEL)
IN THEATRES 25TH OCTOBER
GRAND DIWALI RELEASE
C
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 NNEX
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From: Shri Chitragupta Welfare Trust <shrichitraguptawelfaretrusi@gmau.

Date: Tue, Sep 20. 2022 at 11:27 AM
Subject. Please Stop the Upcoming Bollywood movie "Thank God
To: sranjan.rajourya@tseries.net>
Cc: srajan.rajourya@tseries.net>, <secy.inb@nic.in>, <marutint@vsnl.com

Shri Bhushan Dua

Super Cassettes Industries Private Limited ( T-Series)
E-2/16, Ansari Road Darya Ganj New Delhi 110002
Email-rajan.rajourya@tseries.net

Sub: Please Stop the Upcoming Bollywood movie "Thank God"

Sir/s,

ease note that the trailer already released of movie Thank God' is quite derogatory and insuiing t G
r a g u p t a , which contains derogatory acts, statements, dialogue, story etc. and the same are not acceptabie at al Dy

this the Kayastna

the Kayastha Community of country, since God Chitragupta is followed and worshiped by
Community.
You are thus, requested to remove the trailer and posters of the said movie "Thank God" from Youlube and otne
electronie platforms forthwith and further not to release the same in theatres / OTT or other Platform across tne

country.

Thanking you,

(DEEPMALA SRIVASTAVA)
Trustee of 'Shri Chitragupta Welfare Trust'
R/o: Kothi No. 62, Block-I, Sector-27, Noida-201301
Mob: 8130956030 / 7289867495

CC:
1. Shri Indra Kumar
Maruti International Studios Private Limited
Add-32 Rock Garden, New Delhi Link Road Andheri Mumbai City MH-400053
marutint@vsnl.com

2. Shri Parsoon Joshi, Chairperson

Films Division Complex, Phase I-Building, 9h Floor Dr. G. Deshmukh Marg, Mumbai - 400026

Email chairperson.cbfc.nic.in

3. Apurva Chandra (Secretary)

Dr. Rajendra Prasad Road, Shastri Bhawan, New Delhi-110001
Email- secy.inb@nic.in

4. Shri Ajay Devgan

5/6, Sheetal Apartments, Ground Floor, Opp. Chandan Cinema, Juhu, Mumbai, MH

Thank God.pdf
329

Tre Cof'y)
 IN THE SUPREME COURT OF INDIA
(CIVIL ORIGINAL JURISDICTION)
L.A. NO. IS Oo21 OF 2022

IN
WRIT PETITION (CIVIL) NO. 8 _OF 2022

IN THE MATTER OF:

Shri Chitragupta Welfare Trust ... Petitioner

Versus

Central Board of Film Certification & Ors. ..Respondents

APPLICATION ON BEHALF OF THE PETITIONER FOR STAY.

To,

The Hon'ble the Chief Justice of India and his companion Justices of the
Hon'ble Supreme Court of India.

The humble Application of the Applicant/Petitioner abovenamed.

MOST RESPECTULLY SHOWETH:

That the accompanying Petition arises out of and against derogatory

1.

expressions, acts, statements, dialogues and insulting images,

videos in and around the character of God Chitragupta played by

Devgan/Respondent No.4, which is evident

Bollywood Actor, Ajay

release of trailer of Bollywood movie "Thank God"

from the

to as "the said Movie/Film'") as is also evident

(hereinafter referred
 26
It is prayed that the
from already released trailer of the said movie.
contents of the Petition be read as part and parcel of the present

for the sake

application and the same are not being repeated herein

of brevity.

2 That the said movie contains various objectionable and derogatory

acts, gesture, talks etc. totally against and on behest of God

Chitragupta, which are not acceptable at all for Kayastha communty

in the country and Hindus or otherwise. Needles to state that the

said God Chitraputa is followed and worshiped by Kayastha

community in India and Hindus, which includes Srivastava, Saxena

etc.

3 It is respectfully submitted that the release of the said movie in

theatres/ cinema halls all over India and/or on OTT platform would

not only harm and cause injury to sentiment of the Petitioner, but also

crores of people of Kayastha community and Hindus and could cause

chaos and thus, peace and harmony in the country could be

disturbed. As such, there is utter violation of Articles 14 and 25 of the

Constitution of India, apart from Section 5B of Cinematograph Act,

1962. Thus, the release of the said movie is liable to be stayed

permanently and the Respondents are liable to be penalized as per

law.
 case on merits as
4. That the Petitioner has an excellent prima facie
succeed before this
well as law and in all probability, is likely to
and injury shall be
Hon'ble Court. Grave prejudice, hardships, loss
caused to the Petitioner, if the stay as prayed for is not granteed

during the pendency of the present petition.

5 That the present application is being made bonafide and in the

interest of justice.

PRAYER

In the facts and circumstances mentioned above, it is, therefore, most

respectfully prayed that this Hon'ble Court may be pleased to, by way of an

ad-interim ex-parte order:

(a) Stay the release of the said movie in theatres/cinema halls all over

India and/or on OTT platform during the pendency of the present

petition; and/or

(c)
(c) Pass such other and further order(s) as this Hon'ble Court may deem

fit and proper in the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS, THE PETITIONER, AS IN DUTY

BOUND, SHALL EVER PRAY.

FILED BY:

(LOKESH KUMAR CHOUDHARY)

ADVOCATE FOR THE PETITIONER
FILED ON: 229-22