The death of a crew member after suffering an electric shock on the sets of
Sanjay Leela Bhansali’s Love & War has triggered discussion around workplace safety in Indian film industry.
While accidents on film sets have periodically sparked calls for reform, India still does not have a dedicated law prescribing how film sets should be planned, supervised and audited from a safety standpoint.
That does not mean film shoots operate outside the law. Instead, productions are governed through a combination of labour laws, workplace safety provisions, criminal law, contractual obligations and permissions issued by various government agencies.
Legal experts say the debate more about whether the existing framework is suited to the different nature of film production.
What laws govern film shoots?
Film production, unlike sectors such as mining or factories, does not have a standalone legislation focused exclusively on on-set safety. Before a shoot begins, producers may have to obtain permissions from multiple authorities depending on the location and nature of filming.
These include approvals through the India Cine Hub portal or directly from state governments and ministries, besides permissions from agencies such as the police, railways, forest departments, municipal authorities and the Archaeological Survey of India (ASI) where required.
The Ministry of Information and Broadcasting (MIB) has also issued guidelines governing permissions for filming at specified locations, particularly those under the Central government.
Alongside these administrative approvals, employment relationships on film sets are governed by the four Labour Codes, including the Occupational Safety, Health and Working Conditions (OSH) Code, 2020, which came into force in November 2025.
The Code brought together multiple labour laws under a single framework and, for the first time, expressly recognised audio-visual production and audio-visual workers within its scope.
Under the OSH Code, an audio-visual worker includes a person employed directly or through a contractor in connection with film, television, advertising, animation or digital productions, subject to the prescribed remuneration threshold. The law also requires written agreements covering health, safety, working conditions, working hours and welfare facilities.
Why is there a gap?
Legal experts say the issue is not that film workers lack legal protection. Rather, the existing laws are broad workplace safety provisions and do not prescribe safety standards tailored to the risks involved in film production.
"India would benefit from a dedicated film set safety framework because existing labour, criminal and occupational safety laws are fragmented and not designed for the project-based, multi-employer realities of film production," said Kaushik Moitra, partner at Bharucha & Partners.
According to him, the biggest gaps include the absence of mandatory pre-shoot risk assessments, designated safety officers, uniform protocols for stunts, electrical work, crowd scenes and minors, as well as a clearly defined chain of command for accountability.
Film shoots differ from conventional workplaces in several ways. Productions are temporary, often involve multiple employers, contractors and freelancers, and move between locations over short periods. Departments handling stunts, lighting, electrical work, rigging and special effects frequently operate simultaneously. This makes coordination more complex than in a permanent workplace.
Moitra said this fragmented structure means responsibility can become difficult to determine when accidents occur. "Film shoots are temporary, high-pressure workplaces involving multiple employers, contractors, stunt teams, technical crews and shifting locations. When something goes wrong, liability often becomes diffused," he said.
Has the new OSH Code addressed these concerns?
There is no single answer.
Debjani Aich, partner at CMS INDUSLAW, said the OSH Code already provides substantive protections because it brings audio-visual workers within the ambit of occupational health and safety legislation.
"The OSH Code applies to film sets where the activity falls under audio-visual production carried out by an establishment," she said. In her view, film crew employees are now covered under the Code and, if its provisions are implemented effectively, workers should receive adequate protection.
Aich said the industry had historically remained in a grey area under employment law, but the inclusion of audio-visual workers in the new framework marks an important shift. Rather than creating another law immediately, she believes the priority should be ensuring effective implementation of the existing provisions relating to working conditions, safety, overtime and welfare.
Moitra, however, argued that while the OSH Code has expanded legal coverage, it stops short of prescribing production-specific safeguards.
"The gap is not that film sets are outside the law; it is that the existing framework does not create a film-set-specific safety regime," he said.
According to him, the Code does not require mandatory risk assessments before stunt, rigging or pyrotechnic sequences, certification for stunt coordinators or riggers, or film-specific limits on continuous night shoots. Instead, productions continue to rely on general workplace safety obligations, contract labour provisions and criminal law where negligence is alleged.
Who is held responsible when accidents occur?
One of the biggest misconceptions after a fatal accident on a film set is that responsibility automatically rests with the producer. Legal experts say liability depends on the facts of each case and is determined by who exercised control over the activity, who created or ignored the risk, and whether legal or contractual duties were breached.
Moitra said criminal and civil liability could extend to producers, production houses, line producers, contractors, employers and responsible individuals, depending on who controlled the set or failed to implement adequate safeguards.
"The production house will usually carry primary responsibility where it controls the shoot, but individual crew heads, contractors or vendors may also be exposed if they ignored or created a known safety risk," he said.
In the absence of a dedicated film safety law, investigations may invoke provisions of the Bharatiya Nyaya Sanhita (BNS) dealing with negligence, along with obligations under labour laws and contractual arrangements. Whether an accident results in criminal prosecution or civil liability depends on the circumstances of the incident.
Is the bigger issue the absence of a law or weak enforcement?
Aich said the OSH Code has already brought film workers within a stronger legal framework, and the immediate priority should be implementation rather than another statute.
"The OSH Code is relatively new and has substantive protections for the working conditions, health and safety of eligible employees, which now include audio-visual workers. If these provisions are effectively implemented and enforced by employers, there will be adequate protections," she said.
Adil Ladha, partner at Saraf and Partners, also believes existing legislation formally covers film workers. The Labour Codes subsumed the earlier Cine Workers and Cinema Theatre Workers (Regulation of Employment) Act, 1981, and recognise audio-visual production within the scope of occupational safety and social security laws.
However, he said the challenge lies in how the industry functions in practice. "A large proportion of film crews work as informal, project-based or contractor-supplied labour. Informal and unorganised workers remain weakly protected in practice despite formal inclusion in the statutory framework," Ladha said.
He added that casual employment, short-term contracts and historically uneven implementation of welfare measures continue to create gaps between legal protections and actual working conditions.
Would a dedicated Film Set Safety Act make a difference?
Experts say a standalone law could help if it addresses risks unique to film production rather than simply repeating existing labour provisions.
Moitra said a dedicated framework should require written safety plans before filming begins, mandatory hazard assessments, clearly assigned responsibilities, emergency medical protocols, safety training, incident reporting, insurance compliance and penalties for non-compliance.
Ladha believes a separate law could add value by introducing sector-specific minimum safety standards, specialised institutions such as a film-sector safety board or inspectorate, and stronger oversight of informal and project-based workers. However, he said the larger issue today remains enforcement of the existing Labour Codes rather than a complete absence of legal powers.
The experts also agree on at least one immediate reform. Aich said safety certification should become mandatory before high-risk shoots involving stunts, pyrotechnics or complex electrical work.
Ladha said while Indian law does not currently require such certification for film productions, introducing pre-shoot safety clearance through rules under the OSH Code would be consistent with its preventive approach to workplace safety.
What do other countries do differently?
Many established film industries rely on sector-specific safety standards in addition to general workplace safety laws.
In countries such as the United Kingdom, film productions routinely carry out written risk assessments before shoots and follow detailed health and safety guidance.
In the United States, industry practices developed through workplace safety regulations and union protocols require extensive planning for hazardous scenes, including stunts and special effects. Australia also follows industry-specific safety guidance for screen productions.
India, by contrast, relies primarily on general labour legislation and administrative permissions. Government rules prescribe how productions obtain filming approvals and comply with location-specific requirements, but they do not lay down a uniform national framework for conducting high-risk shoots.
 "Film set safety in India: What's missing from the legal framework?")
