Glorification Of Stalking In Bollywood

Bollywood is world’s largest film industry in terms of films being produced per year in a  particular country which is 364 films being annually featured(2017). Since its inception from Raja Harish Chandra in the year 1913, it is the only industry in India which has never suffered losses.

But as we all know every coin has 2 sides to it, similar is the case of Bollywood. With the profits being earned by them not only is benefitting our economic status of our country but also its affecting our Social Culture. The biggest problem faced by our country is its illiteracy. Therefore, bollywood is considered to be one of major influences of societal behavior of people due to its wide reach to public. And hence alcoholism, misogyny, patriarchy, commodification of women, etc are the gift given to us by the largest fraternity of film producers in the world.

But the most dangerous amongst them is “STALKING”

The informal way in which stalking is regularly portrayed on display increases alarming questions. If the makers of Toilet feel that the film has a sturdy message against open defecation, can one expect its message is as a lot about making stalking regular or even a favored manner of wooing a female? Specifically, a movie like this one is extra than ‘entertainment’, it’s miles Entertainment-Education

As many would argue, stalking is an old Bollywood trope. The popular number ‘o laal dupatta walli, tera naam to bata’ from Aankhen was the stalking song of the 1990s.

But many popular movies from that era which had stalking as its central plot – such Darr, Anjaam, Daraar and Jeet – still maintained the semblance of a moral compass: the stalkers were accepted as villainous ‘obsessed lovers’ rather than heroes. The compass, it seems, has shifted in the last quarter.

For example in Raanjhanaa, starring Tamilian superstar Dhanush, and the 2003 film Tere Naam, starring Salman Khan. In these films, the stalkers torture and ruin their victims’ lives due to their morbid infatuation before choosing their own passionate end. Ironically, the audiences lapped up the message of selfless love and honesty of the ‘heroes’ and rooted for them. The actors’ craft created a deep sense of sympathy among viewers, edging out the fact that stalking is a purely criminal act.

Legal Aspect

Stalking is considered to be the pre- cursor to many other crimes. In California stalking was recognized as crime back in 1990 but it took us almost 68 years of Independence to recognize it was a mere crime. The Criminal Law Amendment Act, 2013 not only recognized it as a crime but also defined it in the widest way possible under section 354D of the Indian Penal Code which is as follows:


Any man who—

  1. follows a woman and contacts, or attempts to contact such woman to foster personal interaction repeatedly despite a clear indication of disinterest by such woman; or
  2. Monitors the use by a woman of the internet, email or any other form of electronic communication, commits the offence of stalking.[2]

The section as mentioned is quite wide and also describes about the punishment which can be extended up to 3-5 years of imprisonment. The main issue regarding the section was that it is a bail able offence if it is first offence. Justice Verma committee was set up to check whether the validity of the section was present or not regarding the bail ability of criminal to which the committee supported the view of Mr. Shashi Tharoor who was opined that it shouldn’t be bail able because this so called simple offence can be the root was of many other heinous crimes like murder, acid attack, rape, etc. but due to the opposition pressure the first offence was recognized to be bail able.

With development of technology this crime is not only limited to physical stalking but had also added one more facet to it which cyber stalking. In other words “Whoever monitors the use by a person of the internet, email or any other form of electronic communication that results in a fear of violence, or interferes with the mental peace of such person, commits the offence of cyber stalking.” Under section 67, 67A, 66A and 72 of the IT Act, 2000 deals with stalking and its implication and punishments.

Sandesh Baliga Case

In a sensational case from Australia in 2015, an Indian man, Sandesh Baliga, accused of stalking two women in Tasmania, successfully argued that he believed the patient pursuit of a woman would make her fall in love with him since that’s what he’d seen in Bollywood films. He also stated that he learnt the art of stalking from Shah Rukh Khan’s character in the movie Darr. This shows how much impact movies make and have in the lives of people living in not only in Indian society but also in other countries.

Pryadarshini Mattoo Case

The deceased was an aspiring lawyer studying in the prestigious Delhi University where she first met the accused Santosh Kumar Singh, who was her senior in college. He was since his first meeting with was besotted by her beauty and also made many attempts of indecent proposals to her. After sometimes her family lodged FIR against him but still he stalked her every possible where. One day her body was found strangulated at her uncle’s place. After autopsy it was found that she was raped and then murdered and the direct accuse went to her senior. But since he belonged to an influential family residing in Delhi where the incident took place he was granted parole in the year 2012 which is still continuing.

NCRB Report

According to the National Crime Records Bureau, the number of stalking cases in 2015 was 6,266. Yet, these figures likely do not capture the entire scale and horror of stalking. It has been four years since stalking was recognised as a form of violence against women under IPC Section 354D. But the crime is punishable with rigorous imprisonment for a term up to three to five years. The lack of diligent law enforcement is evident in these horrific stalking crimes. According to the NCRB a study was conducted in the Geena Davis Institute on gender media. It was concluded in that, that India is ranked very high in world cinema when it comes to sexualizing women. Also is was stated that the highest number of crimes committed against women in India is in Uttar Pradesh with about 38467 per year and the lowest being in Uttarakhand and Lakshwadweep.


In social learning theory, Albert Bandura (1977) agrees with the behaviorist learning theories of classical conditioning and operant conditioning. Individuals that are observed are called models. In society, children are surrounded by many influential models, such as parents within the family, characters on children’s TV, friends within their peer group and teachers at school. These models provide examples of behavior to observe and imitate.[3]

Cultivation theory was founded by George Gerbner and is positivistic. Cultivation theory examines the long-term effects of television. “The primary proposition of cultivation theory states that the more time people spend ‘living’ in the television world, the more likely they are to believe social reality aligns with reality portrayed on television.”[4] The images and ideological messages transmitted through popular television media heavily influence perceptions of the real world.[5]


  1. Filing Complain to National Commission for Women and the commission will take up the complaint to the police. The commission has been bestowed by the power to form committee in case of urgency. They can also issue summons to accused, witnesses and police reports, to facilitate inquiry. They have also provided their contact numbers at public forum so that, in case of emergency the victim can contact them as soon as possible.
  2. “Atithi Devo Bhava”- it is the slogan followed by the Ministry of tourism in India but its so shameful for us that not only Indians but also foreigners are victims of stalking. In order to protect them the ministry of Tourism in collaboration with Tata Business Support services launched Infoline in 12 different languages for making it user friendly for the foreign tourists.
  3. Online registration complaint by victims.
  4. Zero FIR- this kind of FIR can be filed at any part of India irrespective of its Jurisdiction.


In India stalking can either be physical or electronic via mail, social media profile, etc irrespective of the medium used it constitutes to a criminal offence with an imprisonment of min. 3 years.

Regardless of whether one is working professional or student or housewife- many women in India get stalked on regular basis. Due to the fear of being stalked many women avoid getting out of their house and become pardanashin. In order to avoid stalking women are asked to dress so called “modestly” so that they don’t cater unwanted attention or either are asked to have a male company along with them. Even after independence of 72 years why are still women being caged? Isn’t it the duty og the government to make them feel save? Isn’t duty of the Entertainment industry to make sensible movies? Isn’t the duty of CBFC to take into consideration as to what will affect the social behavior of people?

The problem isn’t that stalking is being shown on the big screen but the root cause is that it is being promoted as heroic gesture.

As discussed above in movies like Darr, Anjam, Tumsa nahi dekha,etc the stalker were shown as the villainous character in the film but from the early 2000s in movies like Sultan, Tere Naam, Raanjhanaa, Ae Dil Hain Mushkil, Rehna Hai Tere Dil mein, Toilet, etc the compass has totally shifted from villains to heroes of the movie. Therefore the rise in number of stalking cases can be seen from the early 2000s.

Hence, it is the duty of the entertainment Industry as a whole to act responsibly because they are not only the world’s biggest film fraternity but also play an important role in educating the society.

Author: Poulomi Goswami, Intern at Khurana & Khurana, Advocates and IP Attorneys. In case of any queries please contact/write back to us at


[1] Criminal Law (Amendment) Act, 2013

[2] Section 354D, Indian Penal Code, 1860


[4]  Riddle, K. (2009). Cultivation Theory Revisited: The Impact of Childhood Television Viewing Levels on Social Reality Beliefs and Construct Accessibility in Adulthood


Leave a Reply

Your email address will not be published.

three × three =


  • January 2023
  • December 2022
  • November 2022
  • October 2022
  • September 2022
  • August 2022
  • July 2022
  • June 2022
  • May 2022
  • April 2022
  • March 2022
  • February 2022
  • January 2022
  • December 2021
  • November 2021
  • October 2021
  • September 2021
  • August 2021
  • July 2021
  • June 2021
  • May 2021
  • April 2021
  • March 2021
  • February 2021
  • January 2021
  • December 2020
  • November 2020
  • October 2020
  • September 2020
  • August 2020
  • July 2020
  • June 2020
  • May 2020
  • April 2020
  • March 2020
  • February 2020
  • January 2020
  • December 2019
  • November 2019
  • October 2019
  • September 2019
  • August 2019
  • July 2019
  • June 2019
  • May 2019
  • April 2019
  • March 2019
  • February 2019
  • January 2019
  • December 2018
  • November 2018
  • October 2018
  • September 2018
  • August 2018
  • July 2018
  • June 2018
  • May 2018
  • April 2018
  • March 2018
  • February 2018
  • January 2018
  • December 2017
  • November 2017
  • October 2017
  • September 2017
  • August 2017
  • July 2017
  • June 2017
  • May 2017
  • April 2017
  • March 2017
  • February 2017
  • January 2017
  • December 2016
  • November 2016
  • October 2016
  • September 2016
  • August 2016
  • July 2016
  • June 2016
  • May 2016
  • April 2016
  • March 2016
  • February 2016
  • January 2016
  • December 2015
  • November 2015
  • October 2015
  • September 2015
  • August 2015
  • July 2015
  • June 2015
  • May 2015
  • April 2015
  • March 2015
  • February 2015
  • January 2015
  • December 2014
  • November 2014
  • October 2014
  • September 2014
  • August 2014
  • July 2014
  • June 2014
  • May 2014
  • April 2014
  • March 2014
  • February 2014
  • January 2014
  • December 2013
  • November 2013
  • October 2013
  • September 2013
  • August 2013
  • July 2013
  • June 2013
  • May 2013
  • April 2013
  • March 2013
  • February 2013
  • January 2013
  • December 2012
  • November 2012
  • September 2012
  • August 2012
  • July 2012
  • June 2012
  • May 2012
  • April 2012
  • March 2012
  • February 2012
  • January 2012
  • December 2011
  • November 2011
  • October 2011
  • September 2011
  • August 2011
  • July 2011
  • June 2011
  • May 2011
  • April 2011
  • March 2011
  • February 2011
  • January 2011
  • December 2010
  • September 2010
  • July 2010
  • June 2010
  • May 2010
  • April 2010