Manto faced trial for obscenity in his writings, three times in British India before 1947 (‘Dhuan’, ‘Bu’ and ‘Kali Shalwar’) and three times in Pakistan after 1947 (‘Khol Do’, ‘Thanda Gosht’ and ‘Upar Neeche Darmiyaan’) under section 292 of the Indian Penal Code (by the British Government) and the Pakistan Penal Code in Pakistan’s early years.[62] He was fined only in one case.