Mallavarapu Lakshmana Kumar vs. Union Of INDIA

Held

The Court held that the issue of enhanced ticket prices for the film 'Sankranthiki Vasthunam' was rendered infructuous as the scheduled shows had already been telecast. Regarding the investigation into production costs and promotional activities, the Court found it to be beyond the writ court's jurisdiction. Such matters fall within the domain of the executive and investigating agencies. The Court stated that it was not viable to order an investigation in a writ petition, especially when the allegations were bald and lacked prima facie evidence. The Court concluded that the petition was filed for publicity rather than public interest and did not warrant the exercise of extraordinary jurisdiction under Article 226 of the Constitution. Therefore, the PIL was dismissed.

Facts

The petitioner, Mallavarapu Lakshmana Kumar, filed a Public Interest Litigation (PIL) challenging the respondents' action of enhancing ticketing prices and the number of shows for the film 'Sankranthiki Vasthunam'. The petitioner contended that the memo dated 08.01.2025, allowing increased ticket rates and multiple shows, violated G.O.Ms.No.13 Home (General-A) Department dated 07.03.2022. The petitioner also sought an inquiry into the film's production cost exceeding Rs. 100 crores and an investigation into promotional hype. The respondents argued that G.O.Ms.No.13 was under modification and that a previous writ petition (W.P.No.7094 of 2022) challenging the G.O. was pending, with an interim stay on online service charges. The Court noted that the shows had already been telecast and that investigation into production costs was beyond the writ court's domain.

Key Issues

1. Whether the memo dated 08.01.2025, enhancing ticket prices and permitting additional shows for the film 'Sankranthiki Vasthunam', is illegal and arbitrary, violating G.O.Ms.No.13 Home (General-A) Department dated 07.03.2022 and the interim stay granted in W.P.No.7094 of 2022? Petitioner's argument: The memo directly contravenes G.O.Ms.No.13 by not specifying rates per show category and imposing fixed rates, especially when an interim stay on the G.O. is in force. Respondents' argument: The G.O. is under modification, and the previous writ petition's stay pertained to online service charges, not the current issue. They also alleged the PIL was filed for oblique motives. 2. Whether this Court should direct an inquiry/investigation into the production cost of the film 'Sankranthiki Vasthunam' and its promotional activities? Petitioner's argument: An investigation is necessary due to the alleged production cost exceeding Rs. 100 crores and excessive promotional hype. Respondents' argument: The PIL lacks merit and is filed for publicity. The respondents did not explicitly address the investigation aspect but implied it was not a matter for PIL.