Regulatory power over cinema licensing includes seat classification and admission-rate control as a reasonable business restriction.

The licensing scheme under the Punjab Cinemas (Regulation) Act, 1952 was treated as regulatory in character, and the authority's power under Section 5 read with Section 9, Rule 4 and licence condition 4A was held to extend to classifying cinema seats and fixing admission rates as incidental terms necessary for orderly exhibition. That regulatory control was upheld as a reasonable restriction on the business right under Article 19(1)(g), because it served the public interest and prevented arbitrary pricing while promoting fair access to cinema tickets. The result was that seat classification and admission-rate fixation were within lawful regulatory power and did not infringe the Constitution.

---

---

Issues: Whether the licensing authority under the Punjab Cinemas (Regulation) Act, 1952, the rules and the licence conditions had power to classify cinema seats and fix rates of admission, and whether such regulation violated the fundamental right to carry on business under Article 19(1)(g) of the Constitution of India.

Analysis: The statutory scheme was held to be regulatory in character. Section 5, read with Section 9, Rule 4 and condition 4A of the licence, was treated as authorising the licensing authority to impose terms and conditions necessary for orderly exhibition of cinematograph films, including classification of seats and fixation of admission rates. The power to regulate was held to include the authority to prescribe reasonable conditions incidental to the licensed business. The restriction was also examined against Article 19(1)(g) and treated as a reasonable restriction in the interest of the general public, supported by the public welfare objective of ensuring fair access to cinema tickets and preventing arbitrary pricing.

Conclusion: The licensing authority had the power to classify seats and fix admission rates, and the impugned regulation did not infringe Article 19(1)(g).

Ratio Decidendi: A statutory power to regulate a licensed business includes the power to prescribe reasonable incidental conditions, including price fixation, where the measure is part of a public-interest regulatory scheme and operates as a reasonable restriction under Article 19(6) of the Constitution of India.

---