Film Award eligibility may be limited to certified films where the rule fits the award scheme's public-exhibition objective.

Film Award eligibility could be restricted to films certified for public exhibition because the certification rule was tied to the scheme's object of selecting films already fit for public viewing; it did not bar production, exhibition, or certification rights and was not unconstitutional or arbitrary. The award policy was also not required to mirror uncensored entry rules used for non-commercial film festivals, since the two programmes served different purposes and different eligibility norms were permissible. Exemptions for Film Institutes and Doordarshan did not create a right to equal treatment, as illegality cannot be claimed as a basis for parity. The challenge to the certification-based entry rules therefore failed.

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Issues: (i) Whether the requirement that entries for the National Film Awards must be films certified by the Central Board of Film Certification is an unreasonable restriction on freedom of speech and expression; (ii) Whether the policy for National Film Awards had to mirror the uncensored entry rules applied to non-commercial film festivals; (iii) Whether the exemption granted to films made by Film Institutes and films entered by Doordarshan created unlawful discrimination.

Issue (i): Whether the requirement that entries for the National Film Awards must be films certified by the Central Board of Film Certification is an unreasonable restriction on freedom of speech and expression.

Analysis: The purpose of the Awards was to select the best films that had been certified for public exhibition, so that the Government assessed films capable of being seen by the public in the form in which they were released. The certification requirement did not restrict the right to make, exhibit, or apply for certification of films. It was a policy choice tied to the object of the Awards and was not shown to be arbitrary or constitutionally prohibited.

Conclusion: The certification requirement was not an unreasonable restriction and did not violate Article 19(1)(a).

Issue (ii): Whether the policy for National Film Awards had to mirror the uncensored entry rules applied to non-commercial film festivals.

Analysis: The objects of film festivals and National Film Awards were materially different. Film festivals served exchange, exhibition, and wider interaction, while the Awards were meant to encourage aesthetic, technical, and socially relevant Indian cinema. Different eligibility norms for different events pursued different objectives and did not amount to discrimination.

Conclusion: The Government was not bound to adopt the film-festival model for National Film Awards, and the policy was not discriminatory on that ground.

Issue (iii): Whether the exemption granted to films made by Film Institutes and films entered by Doordarshan created unlawful discrimination.

Analysis: A litigant cannot claim equality in illegality. The exemptions in favour of Film Institutes and Doordarshan were not shown to furnish a lawful basis for a similar claim by other film-makers. The record did not justify treating those exemptions as a valid foundation for extending the same benefit to all entrants, and the challenge to the certification requirement could not succeed on that footing.

Conclusion: The challenged exemptions did not entitle the respondents to identical relief, and the attack on Regulation 10(d) and (e) failed.

Final Conclusion: The appeal succeeded to the extent that the High Court's invalidation of the certification requirement was set aside, while the direction relating to entry of non-feature films in digital format was left undisturbed.

Ratio Decidendi: A government policy limiting award entries to films certified for public exhibition, adopted to further the object of the award scheme, is valid unless shown to be unconstitutional or manifestly arbitrary, and an unlawful exemption granted in another case cannot be claimed as a matter of equality.

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