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Vengeance in Popular Culture

Summary and Keywords

Vengeance or revenge has been characterized in popular culture in a range of different ways. Within theories of criminology and social psychology, its relationship to retribution has been examined along with notions of deterrence and rehabilitation. Vengeance has been prevalent within a range of various belief systems as well as in myths, legends, and sacred texts. While vengeance seems to be a feature in all cultures, its acceptance as an appropriate response has been less than clear. It has been weighed alongside a preference for forgiveness, and tensions between these two options against harm have come to the fore in more recent times.

A distinction can usefully be made between vengeance undertaken by the state and the community on the one hand, which might be termed the revenge of the legal process and that exacted by the individual or family. The vengeance theme has been a major feature of Western culture in its expression in Greek literature and theater, through classical authors like Shakespeare and Racine to the present day. There is a link to popular literature as well as the more elusive world of popular theater and its occasional forays into the revenge theme.

The major expression of revenge within mass cultural forms, however, has been in film. Initially production codes prevented revenge being shown as having a successful outcome. Since the 1970s, however, a major modern version of portraying revenge that recurs within modern cinema throughout the world has been the vigilante film. This model of vengeance operates on the notion of an individual responding to the failings of the official system of securing proportionate or effective retribution. There are particular recurring features in these films including a disruptive random unlawful event, the law taking its course, a system malfunction, a trigger to revenge, and a coda stressing the efficacy of vengeance. Along with this is a significant subgroup within the cinema of personal revenge, the rape-revenge film. There has been extensive scholarship on this type of film and its rather different elements. A distinction can be made on the basis of the nature and perceived audience between this trope and the wider world of vengeance movies.

There has been relatively limited coverage of the revenge theme in television. The changes in the forms of media provide fresh opportunities for coverage of the vengeance theme in the 21st century. The contrast between the community approach of law and that of the individual seeker after revenge are formally different, but in the end they both involve elements of vengeance.

Keywords: Vengeance, revenge, popular culture, film, television, theater, literature, vigilantism


The term “vengeance,” and its more common daily form “revenge,” are at the core of the crime and its treatment. In covering “revenge” the Oxford Thesaurus suggests equivalents include the word retribution and that it can be used in the phrase “pay someone back.” Words have subtle shades of meaning. The terms “reprisal,” “vindictiveness,” and “spitefulness” are also suggested as equivalents and it is necessary to note that these elements creep into the notion of revenge as “settling a score.” It is, then, clear that prescribing exactly what is comprised in vengeance/revenge has a wide range of possibilities, from the relatively benign to rather more meretricious terms.


Within the scholarship on crime and punishment, a number of rationales have found varying degrees of favor over the years. Alongside the notions of deterrence and rehabilitation of offenders, there has always been a recognition of the importance of retribution as one of the goals of the justice system.1 Kant talks of the rationale of punishment being solely because the criminal has committed a crime rather than for some extraneous reason such as deterrence or rehabilitation.2 The need for the public to feel that the perpetrators of wrongs have had an appropriate punishment meted out to them has been a fundamental cornerstone of practice since the inception of formalized methods of dealing with infractions of social norms. More recently, writers in the field of social psychology have explored the various dimensions of retribution and the need for this to be proportional to the wrong committed.3 The notion of punishment as a good in its own right finds its form in many aspects of social life. It is reflected in both criminal codes as well as in the myths and narratives that have sustained communities in the past. How these expressions of revenge and vengeance on behalf of the community are operated continues to be the very stuff of social and political debate. Within these debates, however, there is also consideration of what the role of the individual as opposed to the community should be. The debates are complemented by a range of portrayals in popular culture of what is the appropriate treatment for transgressive behavior. In this contribution the main recurring themes of these popular culture representations are examined. The popular cultural forms themselves draw on a variety of sources that are noted here.


Revenge and vengeance pervade many traditional texts, oral traditions, and belief systems. Greek mythology, for instance, seems to consist of an endless series of actions and reactions by various Gods to actual harm and perceived slights for which revenge is routinely sought.4 The same kinds of responses are encountered in the Norse and Anglo-Saxon Sagas.5 The tales of the Teutonic Knights laud the actions of those who act out revenge on enemies.6 The narrative of revenge for harm done remains a potent inspiration for those in the entertainment industry from The Magnificent Seven7 to High Plains Drifter,8 Unforgiven,9 and the most recent TV version of the Count of Monte Cristo story, Revenge.10

Perspectives on revenge and its role within civil society also are encountered in many of the sacred texts that guide people’s lives and which are the source of various forms of storytelling. It is fair to say that the various sacred sources on which people may derive their models for action are far from straightforward on the role of vengeance. In different parts of the Bible we find rather different messages. For instance, in an early part of the Old Testament or Torah, this is written:

But if there is serious injury, you are to take life for life

eye for eye, tooth for tooth, hand for hand, foot for foot

burn for burn, wound for wound, bruise for bruise [stripe for stripe]11

This formulation is often taken to mean that harsh and retaliatory treatment should be applied. What the text actually implies is that any punishment or retaliation should be proportionate. That is to say that it suggests limits on what is done. Hence the idea of imposing capital punishment for property offenses, which was prevalent within many legal systems in the 19th century, would be contrary to this injunction. A version of “eye for eye” is found in the Roman lex talionis, which also recognized the alternative to exacting revenge with its acceptance that compensation was acceptable as recompense.12

On the same theme, in the next book of the Old Testament, Leviticus, we also encounter the following:

You shall not take revenge or bear a grudge against the sons of your own people, but shall love your neighbour as yourself13

The New Testament adds to the debate in its direct reference back to the approach of Exodus:

You have heard that it was said “Eye for eye, and tooth for tooth”

But I tell you, Do not resist an evil person. If someone strikes you on the right cheek, turn to him the other also14

This is perhaps not the appropriate location to discuss the various emphases given to the elements of forgiveness within the biblical discussions of punishment for wrongdoing. Suffice it to say that there are sources that can be drawn on to support very different views when revenge is countenanced.

The Koran/Quran shares the same recognition of the right to vengeance alongside a recognition of the virtue of not exacting revenge:

5.45 In the Torah We decreed for them a life for a life, an eye for an eye, a nose for a nose, an ear for an ear, a tooth for a tooth and a wound for a wound. But if a man charitably forbears from retaliation, his remission shall atone for him15

In later legal practice we see this notion exemplified in the Anglo-Saxon “weregild” with its acceptance of the option of compensation for injury along with the suggestion that this was the first option to be exercised.16 In this system, there is a link to notions of revenge for family honor in the recognition that those entitled to payment for harm to the victim covered members of the family.

The Nature of Revenge and Vengeance

Revenge occurs in a variety of contexts and may be enacted by a range of different actors. It is worth noting these differences since they have been expressed in quite distinct ways in popular culture. The kind of revenge with which Western society is most familiar is revenge for wrongs suffered. This may be from the most serious infractions on a person’s integrity such as murder and rape through serious assault to causing financial loss as well as insults to a person’s reputation. Slights may produce revenge of a financial nature where the only aim is to cause loss to the victim.17 Also, to modern eyes in the era of Internet trolls, we find, at the less serious end of the spectrum, dents to a person’s self-image. Although highly personal and no more than the rough and tumble of social life, they may produce a reaction from the victim particularly where a person is held up to public ridicule or shame.

Drawing the line between these and the public humiliation of defamation is one which has faced modern courts with people taking action for perceived imputations of criminality, immorality, or of their character.18 The courts have recognized that to be falsely accused of being, for instance, professionally incompetent or being in financial difficulties may be actionable. The judiciary, however, has taken the view that adults should show some spirit and moral fiber in dealing with the vagaries of life, including insults, and has been loath to award significant damages for mere harm to feelings as opposed to actual pecuniary loss.19

This category of harm to reputation links in with the notion, encountered predominantly in what Kamir refers to as “honor” societies, of insults to honor.20 This involves insults to the family name rather than any immediately tangible damage to a person’s self or property. We see elements of it in “blood feuds” that involve revenge and are currently covered by the police in Britain under the heading HBV (“Honour”-based violence).21 It has, however, been a relatively limited theme in Western popular culture.22

The Avengers23—The Perpetrators of Revenge

It is worth at this point making a clear distinction between the kind of revenge exacted within the legal system and that which takes place when for some reason the system is not used. The essence of the formal legal system as a way of dealing with disputes is that it seeks to replace individual or family redress with a system whereby the poor and weak have the same access to remedies as the rich and powerful and is an essential component of the rule of law.

Revenge and the Legal Process

The way in which “official” revenge or retribution is visited upon the perpetrator varies. In centralized states there can be seem to be no difference between the precepts of the state and local communities. The reality of the operation of power, however, in times of limited communication and absence of central enforcement mechanisms have meant that dealing with wrongdoing has been carried out by less disinterested hands. Those in the local community are more likely to have a rather different agenda.24 Hence, the notions of circuit courts, which we find in many systems dealing with more serious crimes in the name of the central power as opposed to local sectional interests. Such ways of dispensing justice have always had a dual function. They both provide the possibility of a more objective assessment of evidence, shorn of local prejudice as well as allow a demonstration of the power of the central government authority.25

Revenge Exacted by the State

It is, then, according to this account of law’s practice that we find the distinction between serious and petty crime. The former within the remit of the central state and the latter remaining within the realm of local people. In Scotland, traditionally, the crimes of murder, rape, robbery, and willful fire-raising were reserved to the High Court of Justiciary based in Edinburgh. They visited the different parts of the country trying such cases, although the local burgh and sheriff courts had powers in all else including “murder red-hand.”26 For our focus on vengeance in popular culture this is an area of legal practice that has been explored principally within the realm of capital punishment and “prison movies.” Over the years the cruelty and inhumanity of the laws have been exposed in films about punishment. These films have shown the central authorities exacting the state’s revenge on transgressors in a cruel and vindictive way. From the early days of the talkies and the exposure of the crude brutality of the prison system in Georgia in I Am a Fugitive from a Chain Gang27 to the calculated mental torture exacted by the staff in The Shawshank Redemption,28 prison films have shone a critical light on the ways that retribution is exacted by the state.29 Alongside showing the process of incarceration, there has also been a focus on the problems of capital punishment covering both fictional and real-life miscarriages of justice.30

In the more recent past, the focus has shifted somewhat from revenge to that of reconciliation in societies that have undergone transitions from oppression. The approaches have varied with official commissions being set up in such places as South Africa looking to foster forgiveness rather than revenge.31 The context has, in some instances, however, favored identification of conduct as crimes and actions being prosecuted by International Criminal Tribunals.32

Revenge Exacted by the Community

This distinction between the central and the local, however, was not based on the impact on the perpetrator since the local sheriffs and burgh courts had powers to visit serious sanctions on such persons. They could extend to capital sanctions in some instances.33

The slightly different outcomes where the locally based forces of law and order have a major influence on the nature of the punishment of transgressors are seen principally in works dealing with issues of major differences in legal culture around race. In a range of films over the years we find local practices of those enforcing the law playing a major role in the outcome and nature of the justice received by those in breach of local customs. These latter here supplant the letter of the law usually in the form of corrupt or bigoted local law enforcement personnel.34

Revenge Outwith the Law

It is, however, within the extra-legal field that the vast majority of material on vengeance is found. Some scholars have focused on revenge by the victim rather than treat the theme of extra-legal vengeance as a single connected topic. This distinction is explored in the following sections.

Revenge and the Victim

Revenge may be exacted by the victim. This is the theme that has echoed vividly in modern popular culture, as we shall see. Both in mainstream and cult cinema, for instance, revenge by the person most intimately affected by the actions has, as indicated, sparked a huge number of revenge films.35 While other themes are encountered,36 a major trope has been the rape-revenge motif covered below.37

Revenge and the Family

There are, of course, a number of instances, when the role of the revenger is taken by a family member or some other person in solidarity.38 There are subtle nuances of difference between the vengeance of the victim and that exacted by a family or clan member, and a major strand of scholarship has emerged from 1995 onwards on the topic of rape revenge. For our purposes this distinction is worth noting, but it is suggested that the similarities between the actions of victims and related revengers justify dealing with this part of popular culture together.39

In simple terms, vengeance outwith the law is found in the actions of figures seeking to do what the law cannot or will not do. The simplest and most recognized term for such individuals is the vigilante. Before, however, we examine this central figure in some depth, in the most accessible and dominant field of popular culture, film, it is worth briefly commenting on the past and ongoing sources of popular culture.

Vengeance, Culture, and Popular Culture

This text is concerned with how popular culture has represented the actions of the state, the community, and the individual in taking vengeance on the perpetrators of wrongdoing. In many instances, the themes and issues that we find in films, on television, and in popular theater and fiction have their antecedents in serious material that attracts rather less attention.

Just as myths and sagas were replete with the themes of revenge and vengeance, so too classic literature has from its earliest days a deep interest in these themes. We have one early source centered around multiple revenge in Homer’s Iliad. This has at its core the story of Menelaus seeking revenge against Paris for stealing his wife, Helen, along with Achilles hunting Hector down for killing Patroclus. In theatrical texts we find tragedies centered around the themes of revenge and vengeance. Greek tragedies such as Aeschylus’s Oresteia are suffused with the theme from that sought by Clytemnestra to that of Orestes. It is in the ending of the cycle of revenge with the trial of Orestes than we see an alternative to the revenge cycle. This is a theme that pervades subsequent discussions of the role of revenge. Shakespeare employed the narrative device of revenge to motivate many of his protagonists. These range from those remedying a perceived wrong like Hamlet or betrayal like Othello to harm to feelings in The Merchant of Venice and the playing out of “eye for an eye” in Titus Andronicus. Forgiveness is also explored through Prospero in The Tempest and in Corialanus.

France, the home of the revolution of the oppressed in 1789, spawned a 19th-century fascination with revenge centering on the visitation of just desserts to a variety of oppressors. In Dumas’ The Count of Monte Cristo, we have the subtle revenge of Edmond Dantès on the men responsible for his false imprisonment using, among other things, his financial aplomb to engineer ruin. A more direct general social critique is found in Victor Hugo’s Les Misérables, which also has as its central theme the tale of Jean Valjean and his pursuit by the vengeful Javert for petty infractions of the law. These are of particular interest in the link between literature and popular forms of culture. The narratives have resonated with mass audiences by way of film and musical theater and been among the most successful creations in these fields. The Count of Monte Cristo has inspired no less than 30 films and television series based on the story as well as inspiring versions of the story by such mass market writers as Jeffrey Archer.40 The musical Les Misérables has garnered huge audiences41 and awards42 as well as breaking box office records as both a live stage show and a film.

The theme and significance of revenge crops up again and again in literature from Edith Wharton’s ghost story Kerfol in 1905 and Susan Glaspell’s Trifles and A Jury of Her Peers43 to F. Scott Fitzgerald’s The Great Gatsby and shows no signs of altering its popularity as a source for character motivation. It is in this context, then, that we can consider the ways in which revenge and vengeance appear in mass or popular culture. The greatest attention is given to film since this is the area where we find most examples of vengeance and where it is most memorably portrayed time and time again. It does, however, come in other forms, which preceded the dominance of film.

Popular Theater

The theme of revenge, as noted, is encountered in many Greek and Shakespearean tragedies. It has proved a generally less compelling subject in popular theater but there are some notable exceptions. J. B. Priestley’s An Inspector Calls (1945) with its notion of bringing to account those responsible is another version of revenge, albeit of a strange supernatural kind with the inspector’s identity never being made entirely clear. He represents some kind of community conscience and while he does not mete out justice, he is its personification.

Related to the justice system, one of the mainstays of popular theatre during the 20th century and into the 21st has been the mystery murder or “whodunit.” The driving force behind the perpetrator has often been financial gain,44 jealousy,45 and true love,46 but revenge sometimes lies at the back. In the recent professional productions of the Agatha Christie Theatre Company between 2006 and 2015 the theme of revenge crops up. The contrast in terms of the kinds of revenge is marked. One is a cold calculated elaborate ruse in the stage version of the Poirot mystery Five Little Pigs, Go Back for Murder (1960). Here the murder is committed out of revenge by the spurned mistress of an artist.47 By contrast, in Witness for the Prosecution, the treatment of faithful Christine Helm by the heartless Leonard Vole is the theatrical denouement of the play. Here we see the response of the woman whose cunning artifice has secured the acquittal of her beloved. Betrayed by him for another younger woman, she responds efficiently and effectively with the knife with which he himself had committed murder. She has her revenge in the most spectacular and public way. It is not only Sir Wilfrid Robarts who is on her side. So too, from experience, is the mesmerized theater audience. Not all of Christie’s revenge takers are as emotionally charged.

And Then There Were None started out as book in 1939. It was adapted for the stage and opened in 1943. It has been filmed three times: in 1965, 1975, and 1989, and a television version was produced in 2015.48 It features a motley group of people brought together in a remote isthmus, cut off from the outside world by bad weather. The group gradually sees their numbers fall as dead bodies become the order of the day. When we are down to only two survivors the motive for the deaths is made clear by the killer—who is in fact one of the “deceased.” The judge in the scenario is seeking revenge for reasons that are confusing but are all part of the desire of the author to provide a “perfect insoluble” murder mystery, with revenge at its heart.

The plays based on the work of legal author Henry Cecil also feature people who have been wronged gathering together a group of people to subject them to some kind of sophisticated vengeance. William Saroyan and Henry Cecil’s Settled Out of Court49 centers on the revenge of a escaped convicted murderer determined to prove his innocence and take revenge on those who had framed him. As with so many of Henry Cecil’s better stories, there is a twist in the tail. We find this in a further stage collaboration, this time with Felicity Douglas, based on another Cecil book, Alibi for a Judge.50 The convoluted plot seems to revolve around whether the wife of a man accused of bank robbery is trying to extort money from the judge in the case, take her revenge on him, or actually trying to clear her husband’s name. Again all is revealed at the very last moment. Finally, the link between vigilantism and revenge is covered, in a slightly bizarre light-hearted stage adaptation of an earlier Cecil novel in According to the Evidence.51 It is clear, then, that revenge is a theme that theater audiences encounter from these providers of popular stage thrillers.

Popular Fiction

The extent of popular fiction makes a satisfactory assessment difficult to realize. At present it would seem from an examination of the works of writers as varied on law, crime, and justice as Agatha Christie, Henry Cecil, and John Grisham that vengeance and the exacting of revenge are popular and ever-present themes. The prodigious murder mystery output of Agatha Christie between 1920 and 1976 almost inevitably lead some of the killers’ motivations to have been revenge. Revenge too makes its appearance although as in her plays they range from true love52 to simple greed for money.53

In addition to his plays, Cecil is perhaps best known for his light legal fiction. These center on the travails of various lawyers and the machinations of the legal system. A particular mixture of avarice and roguishness motivates most of Cecil’s “scallywags.”54 Some of his work is, however, rather more serious in tone and involves people with the motive of revenge. These include a vigilante killing of a murderer of women on whom the police failed to get proper evidence,55 and a judge killing a man bent on revenge himself.56

From the very start of his writing career the legal thriller writer John Grisham has employed vengeance as a primal force. This has included the revenge reaction to the rape of a daughter57 and domestic abuse58 to a tobacco-induced premature death of a loved one.59 In a rather lighter mood, in her Kinsey Milhone private investigator series, Sue Grafton has selected a letter of the alphabet to supply her title. She started with A is for Alibi and the series reaches its conclusion in 2019 with Z is for Zero scheduled for release then. Her 2011 title V is, of course, V is for Vengeance and deals in a subplot with the revenge of a woman for her husband’s infidelity.60 As the author herself put it, “I know there are people who believe you should forgive and forget. For the record, I’d like to say I’m a big fan of forgiveness as long as I’m given the opportunity to get even first.”61

Revenge Themes in Film62

The index to the 2015 VideoHound Guide to Films suggests that under the broad heading of “revenge,” there have been something in excess of 1,000 films.63 This appears to be the largest category in this comprehensive guide and suggests that this is, indeed, a theme that permeates the most influential sector of popular culture. These films range from influential and lauded films with major directors and stars like John Ford64 and Alejandro González65 to “straight to video” gorefests with little artistic merit and a specific target audience.66 There is, as the Film Guide numbers suggest, much in between like Straw Dogs67 and Outrage.68

For the purposes of this section the focus is on those films that cast some light on the relationship between law and the act/s of vengeance. Cape Fear and its remake,69 for instance, provide a fascinating contrast between what we might term “simple revenge” and “principled revenge.” The filmmaker, Martin Scorsese, altered the original story of the resentful ex-convict Max Cady seeking revenge on the lawyer who had been the witness at his trial. In the later version we see that the system, in the form of that lawyer, had denied him a fair trial. His revenge has a rationale rather than merely being an act of spite and anger as the first film showed. Changing Lanes,70 by contrast, features a lawyer and insurance salesman who get into a spiral of revenge after they have a minor car accident when both are on their way to separate crucial appearances in court cases. It starts with a perceived slight by the lawyer who just wants to buy his way out and is taken to be disrespecting the other motorist and escalates out of all proportion to the original conflict.

The kinds of triggers to actions of revenge range from physical attacks on the victim or a member of their family71 and bullying72 to hurt feelings by someone ending a relationship.73 The victims are usually those directly involved in causing the perceived harm74 or someone taken to represent institutional harm.75

Vengeance, in order to comply with the Production Code,76 is perforce at the core of many westerns from High Plains Drifter77 to Django Unchained.78 In the former a mysterious stranger takes revenge on the townsfolk who allowed the death of their previous marshall, Jim Duncan. This includes an episode in which part of the revenge involves rape as part of the price one of the townswomen must pay. In the latter the bloody revenge is on a former slave owner by his ex-slave whose wife has been taken too. The notion of revenge both under the law and outwith its formalities is encountered in True Grit. Here the protagonist, the young Mattie Ross, seeks to bring her father’s killer to justice to face trial. She describes it, though, in terms of an act of revenge.

People do not give it credence that a fourteen-year-old girl could leave home and go off in the wintertime to avenge her father’s blood but it did not seem so strange then, although I will say it did not happen every day79

These themes of revenge are not confined to the cinema of Hollywood but are encountered in the work of other major film producers. In Europe from Swedish films by classic directors like Ingmar Bergman80 and modern “blockbusters,”81 to French cinema the vengeance trope is encountered.82 More recent developments in the new cinema industries have also seen revenge featuring with notable contributions from the Japanese83 and South Korean film industries.84 Revenge has also been a theme of black comedies ranging from Kind Hearts and Coronets85 to the most recent version in The Dressmaker.86 What unites these distinct offerings is the impetus for revenge. This has its source in the treatment of a woman by a community drawing on a hypocritical and cruel stance centered on class and a narrow morality. While hugely popular and entertaining, the comedic approaches have less to tell us about the interface between the nature of the legal process and its relationship to justice.

A major trope within the vengeance roster are those films that center on revenge for wrongs visited on family or friends that goes unpunished—but where the protagonist knows the perpetrator.87 This has been the most consistent and interesting theme pursued by filmmakers over the last 40 years in the form of the vigilante film.88 This is of particular interest to scholars of the justice system since it throws light on how law commands and loses respect and the resultant problems when the system is perceived as not working. As one of the film posters puts the matter, “What do you do when justice fails.”89 The answer over the 40 years since the 1970s for the victim of crime is to respond on a one-off basis to eliminate the evil that the legal system is unable or unwilling to process effectively. This is a very particular individualist approach that eschews any kind of broader political analysis beyond a distrust of government’s viability. It is a relatively recent but a persistent trope within mainstream filmmaking. The reasons are partly to do with censorship as we shall see.

The Vigilante in Film

The Emergence of the Vigilante or Justice Figure

The Motion Pictures Producers and Distributors of America (MPPDA), which later became the Motion Picture Association of America (MPAA), adopted a code on March 31, 1930, began enforcing it in 1934, and abandoned it in 1968, in favor of the subsequent MPAA film rating system.90 This industry voluntary self-regulation, known as the Hays Code, sought to protect the viewing public in the United States, and by extension, much of the rest of the world, from what were seen as various malign influences—sex, sacrilege, and socialism as well as miscegenation. These were the principal targets identified in the years between 1930 and the late 1960s. These were the years when the Code and equivalents elsewhere were in full vigor.91 Among the issues that the Code frowned on was the belittling of the legal process and any film where the perpetrator of illegal acts did not get their just desserts. The general principles included this statement:

Law shall not be ridiculed nor shall sympathy be shown for its violation

This was discussed in greater detail:

Crimes Against the Law These shall never be presented in such a way as to throw sympathy with the crime as against law and justice or to inspire others with a desire for imitation.

Specifically any film where revenge was the theme was forbidden:

c. Revenge in modern times shall not be justified.

This was to be subject to some leeway covering the absence of civilization or the rule of law:

Revenge in modern times shall not be justified. In lands and ages of less developed civilization and moral principles, revenge may sometimes be presented. This would be the case especially in places where no law exists to cover the crime because of which revenge is committed.

As indicated this did not preclude the theme of revenge in the historical past and was, as we noted, typically encountered in westerns. The lone stranger coming to town to clean up the corruption and dominance of powerful interests is a theme we encounter time and again from Dodge City92 to Shane.93

The Essence of the Vigilante

After the decline of the Code, vigilantism has flourished in film. The quintessential modern vigilante has been the character of Paul Kersey, played with world weary resignation by the actor Charles Bronson. We are talking about the normal citizen, who if left alone by criminal elements, would have no reason to strike back. The simple revenge theme has cropped up in a whole series of films where the original perpetrators are shown as having no redeeming qualities. Their crimes are done almost for sport as in Sudden Impact (1983) and Eye for an Eye (1995). Here the vigilante seeks to deal directly with a perpetrator whom the legal system has failed to bring to justice. The 21st century also has its variants on this theme in the first decade with The Brave One (2007), Gran Torino (2009), Law Abiding Citizen (2009), and Harry Brown (2009). More recently, in the second decade of the century, we have standard lone vigilantes making their appearance in Vendetta (2013), Seeking Justice (2012) and, in 2014, John Doe: Vigilante, A Walk among the Tombstones and The Equalizer.

The term “vigilante” is also sometimes bestowed on government operative agents “on the edge.” Those operating loosely as agents of the government like John Rambo (First Blood (1985); Rambo: First Blood Part II (1985); Rambo III (1988)) but with a cavalier disregard for procedure are not really vigilantes any more than the government spy James Bond, or special operative John McClane in the Die Hard franchise from 1988 onwards. These are merely servants of society who are boldly going where others fear to tread in protecting the status quo and the lawfully constituted authorities rather than acting as vigilantes ignoring or bypassing the law.

There is also the related theme of disaffected legal system personnel who operate in ways that do not meet the expectations of their superiors. One would include within this group “gung ho” police operatives like Axel Foley (Beverly Hills Cop (1984)) and Beverly Hills Cop 2 (1987) and Martin Riggs in the Lethal Weapon series from 1987 to 1998. Again the term “vigilante” has been applied to Harry Callahan of the Dirty Harry series with his cavalier attitude to the rights of suspects. They still operate, however, within the framework of police powers. Magnum Force (1973) illustrates that, while Callahan is casual about the use of violence, he is not a self-appointed righter of wrongs. He is distinct from the gang of cops who urge him to join them in dealing with those whom the law’s technicalities have set free. He is just “doing his job.” Cutting procedural corners is simply his way of enforcing the law for all, not just looking to his own set of standards. Although, like Kersey, often seen as a vigilante, Callahan in The Enforcer (1976), Sudden Impact (1983), and The Dead Pool (1988) metes out justice in a way that is violent but within the framework of his police role. He meets deadly force with deadly force rather than engage in personal revenge. Finally, in The Dead Pool (1988), his victims are seeking to kill him and those he is protecting, and it may be significant that the series ends when Callahan appears to step over this line and actually does take revenge on a perpetrator.

The blandishments that Callahan rejected to become a vigilante were also offered in an indirect way to Judge Steven R. Hardin in Star Chamber (1985). His decision to join this self-appointed group of professional judges to “retry” those whom the legal system had not convicted provides an interesting potential for discussion of the relationship between legal procedures, the rule of law and justice. This discussion within the film is, however, somewhat truncated and we get for a major part of the film instead a chase thriller when the wrong men are identified as the Star Chamber’s next victims.

There is also a clear connection between some of the aims of the vigilante—securing of justice by means outwith the normal channels of the justice system—and those of the romantic outcast figure encountered in many cultures, the social bandit. The most obvious examples would be the gangsters of the Depression. From Bonnie Parker and Clyde Barrow and the Barker Gang to John Dillinger, Baby Face Nelson, and Pretty Boy Floyd, their robberies of banks do not seem to have been undertaken with any other goal than personal enrichment but were widely applauded. The exploits of Charles Floyd, for instance, were encapsulated in the Woody Guthrie song, The Ballad of Pretty Boy Floyd, with the lines suggesting that there was an underlying socially conscious aspect to Floyd in contrast to the relentless exploitation of finance capital.

  • But a many a starvin’ farmer
  • The same old story told
  • How the outlaw paid their mortgage
  • And saved their little homes.94

As Guthrie concludes, the difference between the robbery of the bandit and that of those operating an exploitative financial and legal system has never been easy to distinguish:

  • As through this world you ramble
  • You see lots of funny men
  • Some rob you with a six gun
  • Some with a fountain pen95

The power of the social bandit theme lives on and is found in the Michael Mann film Public Enemies (2009). Here we see that the supportive public reaction in banks to the exploits of the Dillinger gang were such that they were seen as modern heroic Robin Hood figures counterposed to the unfeeling world of finance capital. This had particular resonance following the latest crisis of capitalism in the post-Lehmann Brothers banking meltdown in 2008.

There are also elements of individuals operating in ways that are sometimes casually referred to as vigilantism but who are not, in reality, vengeful seekers after justice. These include the individual under stress. It is worth making a distinction between the vigilantism of personal justice, which has something to say about the nature of inadequate law, and those individuals who tip over into mental unbalance and take on the world like Joe Curran in Joe (1970), Travis Bickle in Taxi Driver (1976), or D-Fens in Falling Down (1992). Here their rage is directed against the whole system rather than an individual act. Their actions may be triggered by a specific event, but it is the social order they are kicking against in their fury. Avenging one single action will probably not be enough.

The Creation of “Legality” and the “Collectivist Vigilante”

One of the reasons why the Hays Code made a distinction between modern revenge and the historical versions has to do with the recent emergence of the link between law and democracy. There is a shift from random lawlessness and individual responses and the emergence of official local law enforcement officers representing the community rather than protecting the interests of the rich. This is the very essence of the Western genre. Hence, versions of group action also crop up in a way that is akin to lone vigilantism. The Revengers (1972) is an example along with The Magnificent Seven (1960) and (2016)96. Here we move into the replacement of random lawlessness and individual response to it, to a community perspective. In time, as The Man Who Shot Liberty Valance (1959) shows us, the lawyer-turned politician, Ranse Stoddard, replaces the frontier gunslinger Tom Doniphon. The dystopian nightmare of Mad Max (1980) and Mad Max: Beyond Thunderdome (1985) is where, in a post-Apocalyptic future, we return to this reliance on the individual in place of a consensus-based law enforcement.

The introduction of the formality of the law places the individual justice figure into an ambivalent position in relation to the procedures and processes of law enforcement. Hence, like the Hays Code, we can see the moral protagonists in Shane (1953) and in Hannie Caulder (1971) not as vigilantes but as proto-law officers. In the modern world, the reverse could be said to be appearing. In the western, The Man Who Shot Liberty Valance (1959), the random gun justice of Tom Doniphon was replaced by the legislature and state-sanctioned enforcement of Ranse Stoddart. In the modern cinematic world, the challenge to the inadequacy of lawful policing comes from a series of individuals seeking solutions on an ad hoc basis in the person of vigilantes like Paul Kersey, Karen McCann, and Erica Bain. This has had a resonance that collectivist actions by the likes of the Gulabi Gang in India and Los Justicieros de la Tierra in Mexico have not enjoyed thus far in popular culture.

The Modern Vigilante Film Assessed

The essence of the modern vigilante film is to pose questions about the nature of justice in a much clearer way than occurs in the traditional courtroom drama but in the context of a thriller. What we get is the revenge motif with a family context. The vigilante focus tends to have more time devoted to moral conundrums and ambiguities than we find in the run-of the-mill trial movie. The courtroom dramas may also contain thriller elements but tend to be centered on the skill, inadequacy, or personal crisis of the major lawyer protagonist. The moral center is often not in dispute—is the accused actually innocent of the crime? How will the legal team for the “David” side manage to overcome the obstacles they face? How will they establish that there is evidence to exculpate their client or to prove that the other side has breached their duties, for instance, not to pollute as in, for instance, A Civil Action (1999) or Erin Brockovich (2000)?97

Vigilante films, by contrast, are about what ordinary citizens do when the justice system does not meet their expectations and fails them. The extent and level of debate about these complex moral dilemmas is variable. Some return to the theme while others simply use the notion of “justice denied” as the catalyst for a thriller. This section focuses on the films that have been most successful in terms of box office, which have major stars and where a recognized director is involved. There are many other films with a vigilante element or where the same kinds of themes appear and a full overview of the area would permit these more coverage. In fairness, many of these are concerned with system challenges rather than simply individuals. The films discussed are representative of the other lesser films. We now look at the conventions that can be seen in the most important films in this subgenre of thrillers that center around a question at the heart of the justice system when wrongdoing is met with extralegal force. This is encapsulated in the question posed on the poster advertising the film The Brave One (2007): “How Many Wrongs to Make it Right?”

Narrative Conventions

The vigilante narrative conventions involve the contrast between the normality of family life and the disruption that assails it and a series of events that befall the luckless family resulting in there being a vigilante response. This succeeds allowing an orderly return to normal life.

Setting the Scene

The opening scene of the modern vigilante film shows the protagonist in their natural environment. This is invariably an ordinary decent family. We get just enough clues about the lives of the family to infer that this is a happy setting with a bright future beckoning. The family is going about doing ordinary day-to-day tasks of shopping, for instance. In Death Wish (1974), Paul Kersey’s daughter and wife have returned from getting the groceries and in Law Abiding Citizen (2009), father and daughter are both constructing gifts for the mother. In Eye for an Eye (1995), we see the excited preparations for a birthday party. In the most elaborate setup we see the home movies of the family growing up from birth through birthdays to near adulthood in Death Sentence (2006). Home movies of a contented childhood also feature in the less generic vigilante themed film Dead Man’s Shoes (2004). The vigilante movie introduces this notion of the family in both a traditional form as with a wife and children as in Eye for an Eye (1995), Death Sentence (2006), and Law Abiding Citizen (2009), as well as a proto-family of vulnerable workplace colleagues in The Equalizer (2014). Even when the vigilante is a senior citizen we see evidence of past happy memories with family photos in Harry Brown (2009).

The Disruptive Random Event

Into this calm and ordered world, there is a sudden and unexpected irruption of stranger violence. The violence is almost always irrational. It is usually unexplained. The perpetrators are evil personified. They have no obvious redeeming social features. They are killing for thrills. In the case of Death Sentence (2006), they are doing this as part of a gang initiation rite or in Harry Brown (2009) because society has no role for them. They may be laughing “crazies” as we find Death Wish (1974) and Law Abiding Citizen (2011) or quiet, seemingly normal “loners” as in Eye for an Eye (1995). At best they are flagrantly irresponsible, taking risks with innocent lives that we see in The Fourth Angel (2002) and The Equalizer (2014). They are classic examples of “stranger danger,” which statistics tell us are far less likely to visit violence upon us than members of our immediate family or people whom we know98.

The Law Takes Its Course

The essence of the perpetrators is that they should be in some way incompetent at evading the police and be immediately apprehended. They are charged and subjected to the rigors of the law in the apprehension phase of the justice system. This is the essence of the vigilante film. The legal system is shown to have the potential to apprehend. This aspect of the law’s operation appears in vigilante films to be in sound working order as shown in Death Wish (1974), Eye for an Eye (1985), Death Sentence (2004), and Law Abiding Citizen (2011). The problem is what has happened to the court system. There is a slight variation in British vigilante films where we find that the problem arises because the prosecution authorities decline to take action and the matter does not reach the courts either for lack of reliable evidence in Dead Man’s Shoes (2004), Harry Brown (2009), and Vendetta (2013) or a jurisdictional technicality in The Fourth Angel (2002). The law, then, is shown as operative but also frequently compromised in the adjudicative phase.

The System Malfunctions

The ease with which the malefactor is apprehended is in sharp contrast to the effectiveness of the trial or adjudicative phase. The conviction fails to materialize and the malefactor goes free. Plea bargaining or restrictive rules on the admissibility of evidence conspire together so that the malefactors are subjected to either no penalty or a mockery of what might reasonably have been predicted. Perhaps this is why the perpetrators are so casual about evading capture since they know that the conviction rate is so low and the system a joke. This theme is found in almost all the films in one form or another. It can include the problem of the adequacy of evidence (Death Sentence, 2006). Other problems range from human foul-ups such as failing to provide the defense with DNA records (Eye for an Eye, 1995) or being unable to use DNA evidence to convict both murderers and having to accept a plea bargain from one of the accused (Law Abiding Citizen, 2009).

Tentative Revenge Reaction Suppressed

The initial reaction of the affected individual is to accept the situation and try and get on with life. The victim is not a natural revenger. There is more to life than feuding and revenge. Paul Kersey goes back to designing buildings in Death Wish (1974). Karen McCann attends a self-help group in Eye for an Eye (1995) dealing with the loss of loved ones and her first thoughts are not of revenge. Erica Bain, the radio presenter in The Brave One (2007), indeed, gets on with her life and returns to work. Even distraught Harry endures the pain of missing his wife’s death through the danger from local thugs preventing him reaching the hospital in time in Harry Brown (2009).

Trigger to Revenge

There is, however, an event that shakes the victim out of their lethargy. There is a realization that something must be done. Unchecked evil raises its ugly head and our protagonist is forced to do something or is put in a situation where action becomes inevitable. Karen McCann seeks counseling for her grief and it is only when she sees the murderer planning and then successfully carrying out another similar crime that she determines to get a gun and simply avenge her own daughter in Eye for an Eye (1995). In The Brave One (2007), the victim Erica Bain finds herself in a convenience store that is being robbed and responds to the threat to herself and the store owner. She does not seek out evil. It comes to her not just once but twice. Spurred by her unexpected confrontations with further evil she determines to put right the original wrongs she has until then borne. Harry Brown (2009) does nothing about the people terrorizing the housing estate where he lives until the death of his friend leads to a confrontation with a mugger and his accidental rediscovery of his Marine training skills. Up until that moment he looks like a frail and frightened pensioner with emphysema.

Successful Elimination of the “Evil”

Normally the amateur victim manages to outwit the perpetrator whether or not it is museum administrator, Karen McCann (Eye for an Eye 1995); civil servant Jack Elgin (The Fourth Angel 2002); or radio program maker Erika Bain (The Brave One 2007). They may turn out to have hidden abilities as a killer or be drawing on their hitherto hidden past. In Law Abiding Citizen (2009), Gerard Butler’s Clyde Shelton turns out to have been a government operative while Michael Caine’s pensioner Harry Brown (2009) has been a Marine and gets out his old knife and obtains a weapon. Denzel Washington’s Robert McCall has been involved in dark ops for the government in The Equalizer (2014) as has been Danny Dyer’s Special Ops interrogation specialist, Jimmy Vickers, in Vendetta (2013). This is the basis for the success of the vigilante film that allows a true thriller film to be operated within the framework of a moral revenge drama. This spells nemesis for those who appear to have escaped the clutches of the law. The perpetrators are brought down to earth in bloody confrontation. There is no opportunity for them to reflect on their past actions and to repent. Vengeance is exacted in a range of bloody ways. Sometimes these are appropriate to the nature of the original crime as in the burning alive of the gang leader in Vendetta (2013), but this is more a feature of the rape-revenge roster discussed below.


There is a brief moment for reflection after the elimination of the “evil.” This “final scene” is one which seems to valorize the actions of the vigilante. The vigilante escapes the wrath of the law. There is in many instances connivance by the representatives of the forces of law and order to ensure that the vigilante escapes any punishment for their actions—from Paul Kersey, through Karen McCann and Erica Bain to Jack Elgin and Harry Brown—we are left to cheer the moral actions of the vigilante. Not only have they had their revenge on the perpetrator but they have been allowed to return to their normal proper law-abiding lives. This ranges from simply surviving to live another day (Eye for an Eye, 1995; Outlaw, 2007; and Harry Brown, 2009), sunning oneself on a yacht (The Fourth Angel, 2002), or taking up the role of vigilante in a new location (Death Wish, 1974; Vendetta, 2013). Vigilantism by part-time amateurs works. The only vigilantes who pay for their actions, and die, are the ones for whom life is already ended—physically with terminal cancer (Gran Torino, 2009) or psychologically with suicide (Dead Man Shoes, 2004) or at worst the ending is ambivalent (Death Sentence, 2007).

The Revenge Dilemma in the Vigilante Film

The advantage the vigilante film has over the traditional courtroom drama is the ability for it to be set firmly and credibly within the action movie genre. There is extensive use of chases and action sequences. This is not the land of suits, strategies, and gavels. Here we have tension-heightening music and short bite—sized discussions of the morality of acting or not acting. It does not involve an extended reflection on the human condition that we find in, for instance, Judgment at Nuremberg (1961) or A Man for All Seasons (1966), but it does have recognizable bad characters against whom the reasonable citizen might want to act. The revenge reflex is to an extent intellectualized and the nature of justice and its source assessed. There is even in the final shot of Seeking Justice/Justice (2012) a suggestion that a form of vigilantism has subverted the whole legal process with widespread vigilante actions being operated through a shadowy Matrix-like underground. The mild, reluctant avenging victim Nicolas Cage is given a codeword to know that he is among those who offer mutual aid and carry out revenge attacks in the style of Hitchcock’s Strangers on a Train (1951) where unconnected people “swap” victims. He is required to kill a sex offender, which he only manages to do by accident. He is arrested for murder but released when he is invited to complete the code phrase of the organization “The Hungry Rabbit Jumps.” Everyone it seems is involved. The victim whose death he caused turns out to have been a reporter investigating vigilantes. A complicated story of blackmail unfolds at the end of which it seems vigilantism pervades the whole of the justice system.

These vigilante films are standard mainstream fare available in today’s multiplexes. The directors of these vigilante films were also major figures such as John Schlesinger, Steven Soderbergh, Shane Meadows, Michael Winner, and Neil Jordan. These are directors whose work has been recognized both at film festivals and at award ceremonies as well as achieving major box office success. The films had in the past and continue to attract such “A-list” stars such as Clint Eastwood, Jodie Foster, Kevin Bacon, Sally Field, Samuel L. Jackson, Michael Caine, Gerard Butler, Jamie Foxx, Nicolas Cage, Guy Pearce, Liam Neeson, and Denzel Washington as well as others with solid box office track records like Chuck Norris, Sean Bean, and Danny Dyer. There is a consistent roster of films over the past 35 years that focus on films that show that the system cannot cope and that the only approach is to settle accounts outwith the formal justice system. These films start with Death Wish (1974)—the original vigilante and can be seen in a range of individual revenge plots mentioned above. This roster covers An Eye for an Eye (1981); Eye for an Eye (1995); The Limey (1999); The Fourth Angel (2002); Dead Man’s Shoes (2004); Red (2004); Death Sentence (2006); The Brave One (2007); Outlaw (2007); Gran Torino (2009); Law Abiding Citizen (2009); Harry Brown (2009); Seeking Justice (2012); Vendetta (2013); John Doe: Vigilante (2014); A Walk among the Tombstones (2014); and The Equalizer (2014).

This, then, is an identifiable genre leading to homages and the like. Some of the films with vigilante themes provide these with a twist. In Hot Fuzz (2007), a quiet peaceful crime-free town turns out to be the result, not of a good mix of effective policing and good citizens but of unbridled vigilantism by the “blue rinse brigade.” In Hero Wanted (2008), an apparent victim vows revenge on the perpetrators of the bank robbery that left an innocent bank clerk dead. All is, however not as it seems. He set up the robbery to have the chance to impress the young female bank clerk who ended up dead. Finally, in Gran Torino (2009), a xenophobe stands up for a group of incomers with whom he appears to have no common ties or interests. Again a twist confounds our expectations when we expect a serious culmination of evil confronted in a shootout. In a similar situation, although seriously outnumbered, Butch and Sundance gun down their opponents in Butch Cassidy and the Sundance Kid (1969). This is parodied in a scene from Blazing Saddles (1974) where the Ringo Kid singlehandedly shoots the guns from the hands of all eight of his opponents. Still expecting something on these lines and drawn in by the poster advertising the film showing Eastwood with rifle in hand, we get instead the ending from Butch Cassidy minus the truth-denying freeze-frame. Eastwood, the hero of Spaghetti Westerns, Pale Rider (1985) and Unforgiven (1992) is, in Gran Torino (2009) cut down in a hail of bullets reaching, not for a gun, but for his cigarette lighter. The police arrive and the gang goes down for his murder. He has shown that there is another way. In the process he has sacrificed himself but we know that he had only a short time to live. It seems to be a wry undercutting of the simplistic appeal of vigilantism. This chimes in with an earlier film directed by Eastwood, Mystic River (2003). Here the issue of the perils of vigilante justice was also subtly raised with the successful avengers suffering in a variety of ways and calling into question the whole vigilante approach. As Miller suggested in his analysis of Eastwood’s earlier revenge work, “revenge is perceived as a reform of the law, not a revolution displacing it.”99

The cinema is suffused with themes of random stranger violence not reflected in crime surveys and statistics where those whom we should fear are members of our family, friends, and acquaintances. These are allied to media themes of the routine malfunctioning of the justice system. Files are lost. The rules obstruct the way of “true justice” with public prosecutors and judges being obsessed with elaborate rules on what amounts to illegal search and seizure. The narrative conventions of the films are simple. The state has failed an ordinary, identifiable sympathetic character whose life we know something about. There is a family. Their happiness has been brought to a jarring halt. Justice is denied to them and if the ordinary citizen cannot get justice, what is to be done? The answer from vigilante cinema is to take back the night. The clear implication of these films briefly surveyed is that revenge as an option “works.” The common final scene in the range of vigilante films is that justice has been effected informally and the world continues. Our justiciero has done what had to be done and the world can return to an even keel. It is little wonder that the Second Amendment to the United States Constitution has so many adherents since not only is there ever-present “stranger danger” but a strong chance that in order for this to be dealt with the individual will have to seize the time. Life can then go on but the “evil” is no more.

There is an interesting development to observe for those looking at the film vigilante in the second decade of the 21st century. We have a continuing preoccupation with the fictional urban vigilante. Most recently we have a novel approach in the marketing of the Australian film John Doe: Vigilante (2014). This premiered in March 2014 and at one level is absolutely standard fare. To quote from the publicity from the producers of the film at that time,

Some call him a hero. Some call him a villain. He’s “John Doe: Vigilante”—an ordinary man who decides to take the law into his own hands. Frustrated with a failing legal system that continues to allow violent criminals to go free, John Doe begins exacting justice the only way he knows how—by killing one criminal at a time. Soon he becomes a media sensation and inspires a group of copycat vigilantes, but who is the real John Doe—a pillar of justice or a cold-blooded murderer? You decide. (Main Street Films)

In what was described as “innovative marketing ploy” the producers of the film launched a free interactive game Vigilante: Speak for the Dead. This was part of a campaign to publicize the film. To do this the producers explained that it enabled users to take the role of a vigilante and disarm other players while also forming powerful vigilante “Crews.” It poses questions such as the following: What’s your idea of justice? Will you steer clear of killing and only target hardened criminals? Or are you a psychotic killer, waxing j-walkers and spending drivers? This marks a recognition by those producing this films that such films have an impact on audiences beyond the time spent watching the action.

The Rape-Revenge film

Alison Young and others also look at the theme of revenge, though with a very different eye. She looks not at the affected family member reaction to trauma but at the surviving victim’s response in her discussion of rape-revenge films.100 This discussion is located within what is a recognizable genre. What she is talking about and examining is a scenario where there is violent revenge by the victim of “a shocking scene of gang rape.”101 This will be “followed by a succession of episodes of violent retribution … after the victim, perhaps having sought legal assistance or the intervention of the police or equally having decided that no effective institutional assistance will be forthcoming decides to undertake the task of revenge.”102 Here, then, is an alternative version of the vigilante film also involving revenge and operating outwith the law. The starting point, however, is different. This focus is narrower. Here we have situation where “the agency of the victim can bring about justice in some form or other.”103 Young’s principal concern is that the depiction of rape in these films is exploitative and unacceptable and it is possible that “the depiction of sexual violence be imagined differently.”104 We should “refuse the invitation to look at the crime image of rape.”105 This reflects Young’s desire to move beyond the focus in some law and film scholarship on narrative tropes. Her preoccupations are with the aesthetics of film and the process of spectatorship. Her notion that the portrayal of rape has pandered to the prurient and should be rejected seems to be entirely well put. The scenes in the films she discusses are evidence that, given an opportunity, filmmakers will dwell on the rape in a way that needs to be addressed.

There is extensive common ground between rape-revenge films and those films in which those indirectly affected by stranger violence to family members seek justice. There is a considerable body of films produced over the years that share the themes Young draws attention to. These are, however, films that are limited in their audience reach. From the very beginning with what Young refers to as the first film in the genre in 1978, I Spit on Your Grave,106 there is a succession of films that are highly violent “gorefests” with prominent coverage of the rape element of the narrative. Over 50 such films are noted in the rape-revenge literature.107 There are occasional exceptions with some mainstream offerings like Sleepers (1996). Although the victims of abuse by prison guards are boys in the criminal justice system, the nature of their abuse is hinted at rather than made explicit here. It has also been suggested that The Girl with the Dragon Tattoo (2009) comes within the genre.108 There are also art-house products like Irréversible (2002), but the majority are for the DVD market with low production values and lacking any noted actors or directors. For the most part they focus on the revenge as revenge without any concern for the consequences and with minimal focus on the post-revenge period. Such is the construction of their plots, their characterization, and their denouements that their likelihood of contributing to the debate about film’s influence on the portrayal of the justice system seems improbable. They are, nonetheless, pertinent to discussions of vengeance and its relationship to the justice system.

The films are largely obscure and well away from the multiplex fare of the vigilante films discussed above. I Spit on Your Grave (1978) is described in one of the film guides as a film “worth zero as a film; lots of violent terror and gory death; totally irresponsibly portrayed”109 as well as being described by Henry as a “B movie.”110 It did not receive a cinematic release in Britain and went straight to video/DVD. Its 2010 remake treads the same path and went straight to DVD. What happens to the victim Jennifer Hills once she has killed the gang of rapists, one by one, we do not know. The film closes on her final act of revenge in both versions. Her relationship to the justice system remains unresolved. Whether or not she will suffer the fate of Aileen Wournos in Monster (2007) or that of Karen McCann in Eye for an Eye (1995) we can only wonder. This is the crucial difference in the focus between the vigilante films examined and the rape-revenge films that share the revenge element. The first set involves an ambivalent and shifting stance in relation to the justice system while the latter proceed on the assumption that it is useless and irrelevant.

Responding to Clover’s work on the alleged pleasures of horror films,111 Read addresses the issue of agency within the rape-revenge genre.112 She sees such films as transforming the victim into heroine.113 Given the dominant nature of the sexploitation trope in such films, whether these films can be seen as a way of making sense of feminism, as Read suggests,114 seems questionable. The rape-revenge film is not limited to the United States. Heller-Nicholas documents the production of such films across different cultures and across different genres.115 She demonstrates that the underlying themes of rape-revenge go well beyond Anglophone cinema and can also be encountered in Argentina, Australia, Canada, France, Germany, Hong Kong, India, Japan, Spain, and Turkey.116 The existence of the rape-revenge theme is also shown to exist across genres appearing in comedy, westerns, and horror films.117 Her focus, though, as she explains, is to explore a “broader cultural confusion about rape generally” reflected in the way in which rape has been screened and to examine “simplistic assumptions about the ethics of rape and its representation on screen.”118 As indicated, that is not the focus of the current article, although I would certainly concur with Heller-Nicholas’s assessment that “many of the female-centred rape-revenge films … addressed in this book are undeniably sensational attempts to profit from the ugly desire to watch sexual violence.”119 Henry, for her part, is concerned with highlighting “affective response and ethical engagement” in her study.120 She looks at the rape-revenge films with a focus on genre and suggests that more recently a revisionist version of the rape-revenge film has emerged. These have a more ambivalent relationship to violent revenge. She cites the role of Adam in Straightheads (2007).121 She also contrasts the more recent work such as Twilight Portrait (2011) and Katalin Vargas (2009) with Lipstick (1976) to make this point.122 Again all the modern films are far from the mainstream and subject to the same concerns as “the classics.” Revenge there certainly is. Contemplation and reflection are absent. So unsympathetic are the perpetrators and so heinous their crimes that the revenge reaction is portrayed as the only option. Given the nature of rape statistics and the likely source, it is to be regretted that these more common domestic experiences do not achieve more extensive, sensitive and sympathetic coverage.123


Revenge has not been a theme that has dominated the television schedules. Indeed, it is hard to actually find much by way of material in which the issue occurs. It is possible to find elements of revenge within some of the action programs centered on the oppression of various groups. So in the1950s, programs aimed principally at children such as Robin Hood and William Tell as well as more adult-orientated adventure material like The Saint and The Four Just Men, we have resistance and in due course the oppressors getting their “just deserts.” While this involves the oppressors being “paid back” and “scores being settled,” there is in these programs little by way of spitefulness and vindictiveness. The “baddies” are crudely drawn and have no redeeming features that might inspire forgiveness. The lawbreakers in the police and detective series between the 1950s and the time of writing were portrayed in a more nuanced way and were driven by various factors including greed and ambition. Revenge as a narrative driver is seldom encountered.124 It is encountered in a short British miniseries Gunrush (2009).125 This deals with the response of a mild-mannered middle-aged taxi driver to the random shooting of his daughter for no good reason in front of him and his wife. The improbable denouement avoids the tricky moral question of whether, having tracked down the killer, the father would have exacted vengeance. Most surprising has been the huge success of the Dexter series (2006–2013). In this we have a classic Jekyll and Hyde figure, Dexter Morgan. By day he is a technical expert dealing with blood spatter patterns for the police, while by night he kills those criminals whom the justice system’s rules has allowed to go free.126

Whether this success presages a whole shift of emphasis is not yet clear. The appearance of characters in successful series, which involve them, inter alia, in getting even—Revenge (2011–2015), Breaking Bad (2008–2013), and How to Get Away with Murder (2014–) suggests this is a distinct possibility.

Reflecting on Vengeance and Revenge

The relationship, then, between the law’s approach to things and that of the seeker after revenge outwith the law comes down to this. The justice system makes possible that there might be acquittal or forgiveness of the accused—the avenger does not but seeks only to punish. Most of the memorable pronouncements on vengeance seem to have stressed these limitations and the attraction of alternatives. From the Talmudic urging to live well as the greatest revenge to Marcus Aurelius’s suggestion that the best revenge is to be unlike him who performed the injury,127 a higher plane is reached from avoiding taking revenge. Sir Francis Bacon, for his part, further acknowledged the attractions of revenge but suggested that one achieved more by avoiding this simple response.

In taking revenge, a man is but even with his enemy; but in passing it over, he is superior 128

You would probably not guess that this was so from exposure to the representation of revenge themes in popular culture.

Review of the Literature and Primary Sources

There has been since the mid-1980s a rapid growth of published material by scholars on the relationship between law and popular culture. A good deal of this interest has been generated by legal scholars and this has had an important influence on the questions asked and approach taken in the literature. Much work has been on the ways in which looking beyond the legal text can provide both interest to students of law as well as an insight into the sectional influences at work on the content and application of the law. This had its roots deep in the notion that law and lawyering is about more than mere rote learning of rules and following these precepts blindly. From the middle of the 20th century, legal education had stressed that the beliefs and perceptions of those applying the law, whether in the courts or on the streets, had an important influence on how law operated.

This focus shifted somewhat when scholars started to examine legal culture. What underpinned the beliefs and perceptions of those operating the justice system and what precisely were these influences? Essentially the interest proceeded from a recognition that, for instance, the judiciary were largely male, white, and from privileged backgrounds socially and educationally and how this tied in with the kinds of decisions they came up with when dealing with such litigants as organized labor or the poor. Although some of these attitudes could be assumed to stem from the class background of the judiciary and the police, this legal culture provided only a very broad and not always satisfactory explanation since in areas like the rights of women or minorities, a class position was not always readily discernible. The shift of focus for some scholars was to explore more specifically the nature of the popular culture behind the legal culture.

Developments have been uneven and with varied emphases in different areas. There has not been a concerted and organized movement of legal scholarship although some writers have interpreted the disparate work on film, for instance, as “ the law and film movement.”129 Developments have not been neat and linear. So, although most of the subsequent work has looked at film and television from a cultural studies perspective, this was not the driver in the early studies. Two others major themes have been encountered. One of these has been the impact of film and television on their audiences. One of the earliest texts drew attention to the importance of cinema and the messages of films about law. It noted how these influenced people’s view of the legal system based on research undertaken in the late 1960s and early 1970s by Vicenzo Tomeo. In his exploration of the influence of Italian film on the theme of justice, Il Giudice sullo Schermo (1973), Tomeo was well ahead of other scholars with his interest in the impact of popular culture on beliefs and attitudes of the public. This kind of detailed empirical work has been taken up in a number of studies in the United States, most notably by Podlas on reality television.130 The views of the next generation of lawyers were also covered in a number of studies.131 In addition, a transnational study looked at the sources of law students’ ideas about justice and how these varied between cultures.132 Most recently, further transnational work has been undertaken in a range of distinct jurisdictions to map out exactly what kind of law-centered television programming there is and how this is related to the production and content control systems existing in these countries.133 This empirical work is, however, thus far, relatively rare when compared with scholarship that analyzes the meaning of films and television programs about law and justice.

The early work in English on law and popular culture started from the recognition that the world was so suffused with media images that this was where people actually obtained their knowledge and attitudes in relation to the legal system.134 It was suggested that the extent of programming and coverage was so vast that this must have an influence on how people viewed law.135 Precise empirical support was not sought at this stage, although as noted, work was later done in this field. This early work drew no particular distinction between law and justice as it appeared in film and on television. The published scholarship thereafter focused principally on film and there were no less than 16 monographs and a dozen special journal editions and edited collections that dealt with film.136 Television, by contrast, has been covered in two essay collection and two books (ibid). While much of the work has, understandably, stressed the importance and centrality of the legal personnel and the justice system’s portrayal, there have been explorations from the perspective of film studies. These have emphasized the different techniques that film uses to construct effective narratives.137

The field continues to develop into such areas superheroes and graphic novels138 although the world of Nintendo devices, computer games, and the exploits of those such as Phoenix Wright: Ace Attorney have yet to be explored.139

Further Reading

Asimow, M., Brown, K., & Papke, D. (Eds.). (2014). Law and popular culture: International perspectives. Cambridge, U.K.: Cambridge Scholars Publishing.Find this resource:

    Bergman, P., & Asimow, M. (2004). Reel justice—The courtroom goes to the movies (2nd ed.). Kansas: Andrews and McMeel.Find this resource:

      Denvir, J. (Ed.). (1996). Legal reelism: Movies as legal texts. Urbana: University of Illinois Press.Find this resource:

        Friedman, L. (1989). Law, lawyers and popular culture. Yale Law Journal, 98, 1579Find this resource:

          Greenfield, S., Osborn, G., & Robson, P. (2010). Film and the law: The cinema of justice (2nd ed.). Oxford: Hart.Find this resource:

            Heller-Nicholas, A. (2011). Rape-revenge films: A critical study. Jefferson, NC: McFarland and Co.Find this resource:

              Henry, C. (2014). Revisionist rape-revenge: Redefining a film genre. New York: Palgrave Macmillan.Find this resource:

                Kamir, O. (2006). Framed: Women in law and film. Durham, NC: Duke University Press.Find this resource:

                  Linera, M., & Rivaya, B. (2006). Una introducción cinematográfica al Derecho. Valencia, Spain: Tirant Lo Blanch.Find this resource:

                    Macaulay, S. (1987). Images of law in everyday life: The lessons of school, entertainment, and spectator sports. Law & Society Review, 21, 185.Find this resource:

                      Machura, S., & Robson, P. (Eds.). (2001). Law and film. Oxford: Blackwell.Find this resource:

                        Moran, L., Christie, I., Sandon, E., & Loizidou, E. L. (Eds.). (2004). Law’s moving image. London: Cavendish.Find this resource:

                          Picart, C. (Ed.). (2016). Framing law and crime. New York: Rowman and Littlefield.Find this resource:

                            Puaux, F. (Ed.). (2002). La Justice à l’écran. Paris: CinémAction 105.Find this resource:

                              Rafter. N. (2006). Shots in the mirror: Crime films and society (2nd ed.). Oxford: Oxford University Press.Find this resource:

                                Read, J. (2000). The new avengers: Feminism, femininity and the rape-revenge cycle. Manchester, U.K.: Manchester University Press.Find this resource:

                                  Robson, P., & Schulz, J. (Eds.). (2016). A transnational study of law and justice on TV. Oxford: Hart.Find this resource:

                                    Robson, P, & Silbey, J. (Eds.). (2012). Law and justice on the small screen. Oxford: Hart.Find this resource:

                                      Sarat, A. (Ed.). (2009). Studies in law, politics and society. Amherst: Emerald.Find this resource:

                                        Sarat A, Douglas, L., & Umphrey, M. (Eds.). (2005). Law on the screen. Stanford, CA: Stanford University Press.Find this resource:

                                          Sharp, C., & Leiboff, M. (2016). Cultural legal studies: Law’s popular cultures and the metamorphosis of law. London: Routledge.Find this resource:

                                            Sherwin, R. (2000). When law goes pop: The vanishing line between law and popular culture. Chicago: University of Chicago Press.Find this resource:

                                              Tomeo, V. (1973). Il Giudice sullo Schermo. Bari, Italy: Laterza.Find this resource:

                                                Valverde, M. (2006). Law and order: Images, meanings, myths. London: Routledge.Find this resource:

                                                  Young, A. (2010). The scene of violence. Abingdon, U.K.: Routledge.Find this resource:


                                                    (1.) Hudson, B. (2003), Understanding justice (London: McGraw-Hill Education); Hudson, B. (2007), Punishment and control (Maidenhead, U.K.: Open University Press).

                                                    (2.) Kant, I. (1797), The metaphysics of morals (Cambridge, U.K.: Cambridge University Press); see also Easton, S., & Piper, C. (2008), Sentencing and punishment: The quest for justice (Oxford: Oxford University Press).

                                                    (3.) Gerber, M., & Jackson, J. (2013), Retribution as revenge and retribution as just deserts, Social Justice Research, 26(1), 61–80; see also Vidmar, N. (2001), Retributive justice: Its social context, In M. Ross & D. T. Miller (Eds.), The justice motive in everyday life (Cambridge, U.K.: Cambridge University Press).

                                                    (4.) Hard, R. (1999), The Routledge handbook of Greek mythology (London: Routledge).

                                                    (5.) Magnusson, M., & Pálsson, H. (1960), Njal’s saga (Harmondsworth: Penguin). Also, in the related Anglo-Saxon saga of Beowulf, Princess Signy married Siggeir, the king of the Geats (the people of Beowulf) who then treacherously murdered Signy’s whole clan with the exception of her brother Sigmund, who was imprisoned. He managed to escape. Signy sends her two children by Siggeir to Sigmund, who then kills them. The siblings sleep together and their son Sinfjotli helps Sigmund burn the palace of Siggeir and those inside, including Signy.

                                                    (6.) Mackenzie, D. (1912), Teutonic myth and legend (London: HMV); see also Edwards, C. (2010), The Nibelungenlied: The lay of the Nibelungs (London: HMV).

                                                    (7.) 1960 (dir. John Sturges).

                                                    (8.) 1973 (dir. Clint Eastwood).

                                                    (9.) 1992 (dir. Clint Eastwood); see also 2014 (dir. Lee Sang-il).

                                                    (10.) ABC—from 2011 to 2015 in 4 series and 89 episodes.

                                                    (11.) Exodus 21:23–25; see also Leviticus 24:17–2217 And he that killeth any man shall surely be put to death.18 And he that killeth a beast shall make it good; beast for beast;19 And if a man cause a blemish in his neighbour; as he hath done, so shall it be done to him;20 Breach for breach, eye for eye, tooth for tooth: as he hath caused a blemish in a man, so shall it be done to him again.21 And he that killeth a beast, he shall restore it: and he that killeth a man, he shall be put to death.

                                                    (12.) Buckland, W. W. (2007), A textbook of Roman law from Augustus to Justinian (Cambridge, U.K.: Cambridge University Press).

                                                    (13.) Leviticus 19:18.

                                                    (14.) Matthew 5:38–39; see also Romans 12:19, Repay no one evil for evil … Beloved, never avenge yourselves, but leave it to the wrath of God, for it is written “Vengeance is mine, I will repay, says the Lord.” To the contrary, if your enemy is hungry, feed him; if he is thirsty, give him something to drink; for by so doing you will heap burning coals on his head. Do not be overcome by evil, but overcome evil with good; 1 Peter 3:9. Do not repay evil for evil or reviling for reviling, but on the contrary, bless, for to this you were called, that you may obtain a blessing; Proverbs 24:29, Do not say “I will do to him as he has done to me; I will pay the man back for what he has done.”

                                                    (15.) The Koran (Harmondsworth: Penguin), The Table at 392.

                                                    (16.) West’s Encyclopedia of American Law (2008, 2d ed.) (New York: Gale Group).

                                                    (17.) Wall Street (1987) (dir. Oliver Stone) with the revenge exacted first by Gordon Gecko on Sir Larry Wildman who ends the film with his own retaliation.

                                                    (18.) Norrie, K. (1995), Defamation and related actions in Scots law (Edinburgh: Butterworths).

                                                    (19.) Anderson v. Palombo, 1986 SLT 46 where the judge described the sum sued for—£10,000—as “utterly ridiculous” and awarded £200.

                                                    (20.) Kamir, O. (2006), Honor and dignity in the film Unforgiven: Implications for sociolegal theory (available at sitemaker.umich.ed); Nisbett, R., & Cohen, D. (1996), Culture of honor: The psychology of violence in the South (Boulder, CO: Westview).

                                                    (21.) Guardian, Tues., Dec. 8, 2015—Police fail “honour” abuse victims—report (available at

                                                    (22.) But see Hatfields and McCoys (Kevin Costner and Kevin Reynolds, 2012) and Hatfields and McCoys: Bad Blood (Fred Olen Ray, 2012).

                                                    (23.) Neither The Avengers (1998)—a film version of the 1960s cult TV series nor Avengers: Age of Ultron (2015)—a superhero film—are concerned with vengeance as opposed to the simple righting of wrongs.

                                                    (24.) Exemplified in the drama Fuenteovejuna (1619) by Lope de Vega.

                                                    (25.) Hay, D. (1975), Property, authority and the criminal law, In D. Hay, P. Linebaugh, J. Rule, E. P. Thompson, & C. Winslow (Eds.), Albion’s fatal tree: Crime and society in eighteenth-century England (London: Pantheon).

                                                    (26.) Donaldson, W. (1958), Burgh courts in the history and literature of Scots law (Edinburgh: Stair Society).

                                                    (27.) 1932 (dir. Mervyn LeRoy) with Paul Muni as the hapless victim of twin miscarriages of justice.

                                                    (28.) 1994 (dir. Frank Darabont) with wrongly convicted Tim Robbins resisting the brutal regime with ingenuity and guile and the assistance of Morgan Freeman despite numerous setbacks.

                                                    (29.) Rafter, N. (2006), Shots in the mirror: Crime films and society (2d ed.) (Oxford: Oxford University Press); see also Whissel, K. (2015), The spectacle of punishment and the “melodramatic imagination” in the classical-era prison film, In C. Ogletree Jr. & A. Sarat (Eds.), Punishment in popular culture (New York: New York University Press).

                                                    (30.) The Life of David Gale (2003) (dir. Alan Parker); Let Him Have It (1991) (dir. Peter Medak).

                                                    (31.) Minow, M. (1998), Between vengeance and forgiveness: South Africa’s truth and reconciliation commission, Negotiation Journal, 14(4) (October), 319–355.

                                                    (32.) The International Tribunal for the Prosecution of Persons Responsible for Serious Violations of International Humanitarian Law Committed in the Territory of the Former Yugoslavia since 1991, more commonly referred to as the International Criminal Tribunal for the former Yugoslavia or ICTY—see Jones, J. W. R. D. (2000), The practice of the international criminal tribunals for the Former Yugoslavia and Rwanda (New York: Transnational); The International Criminal Tribunal for Rwanda First Annual Report of the International Criminal Tribunal for the Prosecution of Persons Responsible for the Genocide and Other Serious Violations of International Humanitarian Law Committed in the Territory of Rwanda and Rwandan Citizens Responsible for Genocide and Other Such Violations Committed in the Territory of Neighbouring States Between 1 January and 31 December 1994, Note by the Secretary-General; also published in African Journal of International and Comparative Law, 9(1) (1997), 217.

                                                    (33.) See fn 20 above.

                                                    (34.) In The Heat of the Night (1967) (dir. Norman Jewison); Mississippi Burning (1988) (dir. Alan Parker); Malcolm X (1992) (dir. Spike Lee); A Time to Kill (1996) (dir. Joel Schumacher).

                                                    (35.) See, for example, Hang ‘Em High (1968) (dir. Ted Post); see also for a fuller discussion of this issue, Robson (2016), Beyond the Courtroom: vigilantism, revenge and rape-revenge films in the cinema of justice, In C. Picart (Ed.), Framing law and crime (New York: Rowman and Littlefield), Appendix 2.

                                                    (36.) Red (2008) (dir. Lucky McKee)—when the law fails to provide redress against the men who killed his dog, the owner takes his revenge.

                                                    (37.) See below at fn 98–121.

                                                    (38.) The Searchers (1956) (dir. John Ford) is about revenge and reconciliation.

                                                    (39.) See below at fn 98–121; see also Robson, P. (2016) loc cit.

                                                    (40.) A prisoner of birth, (2008) (London: Arrow).

                                                    (41.) It ran on Broadway from 1987 to 2003 with 6,680 performances and for over 25 years in London’s West End.

                                                    (42.) Three Academy Awards, three Golden Globe Awards, and four British Academy Film Awards (BAFTA).

                                                    (43.) See Law, justice, and female revenge in “Kerfol,” by Edith Wharton; and “Trifles” and “A jury of her peers ” by Susan Glaspell [Janet Stobbs Wrights, Atlantis, 24(11) (June 2002), 225–243].

                                                    (44.) Spider’s Web (1954); Black Coffee (1930).

                                                    (45.) Towards Zero (1956).

                                                    (46.) Murder on the Nile (1944).

                                                    (47.) 1942 book in which Poirot solves the mystery 16 years after the event.

                                                    (49.) (1962) (London: Samuel French).

                                                    (50.) (1960) (London: Samuel French).

                                                    (51.) (1954) (London: Chapman and Hall).

                                                    (52.) Murder on the Nile (1944).

                                                    (53.) Death in the Clouds (1935).

                                                    (54.) Much in Evidence (1957) (London: Michael Joseph); Unlawful Occasions (1962) (London: Michael Joseph).

                                                    (55.) According to the Evidence (1954) (London: Michael Joseph).

                                                    (56.) Portrait of a Judge (1964) (London: Michael Joseph).

                                                    (57.) A Time to Kill (1996) (dir. Joel Schumacher).

                                                    (58.) The Rainmaker (1997) (dir. Francis Ford Coppola).

                                                    (59.) The Runaway Jury (2003) (dir. Gary Fieder).

                                                    (62.) This section draws on my earlier essay on vigilantes in film Robson (2016), see endnote 35.

                                                    (63.) VideoHound Guide (2015).

                                                    (64.) The Searchers (1954) with John Wayne.

                                                    (65.) The Revenant (2015) with Leonardo DiCaprio.

                                                    (66.) The Hills Have Eyes (1977); although they may just be very black comedies—Inbred (2011).

                                                    (67.) Straw Dogs (1971) (dir. Sam Peckinpah), for instance, has both a major director, Sam Peckinpah, a major star; Dustin Hoffman, and much bloodletting.

                                                    (68.) 1993 (dir. Carlos Saura) with a rape-revenge theme; see also Outrage (1998) (dir. Robert Allan Ackerman) where the revenge is for being terrorized.

                                                    (69.) 1962 (dir. J. Lee Thompson). 1999 (dir. Martin Scorsese).

                                                    (70.) 2002 (dir. Roger Michell).

                                                    (71.) Cloudburst (1951) (dir. Francis Searle)—revenge for wife’s accidental death; Kill Bill (2003) (dir. Quentin Tarantino) and Kill Bill II (2004) (dir. Quentin Tarantino) where the bride avenges the men who killed her husband and attempted to kill her on her wedding day; Closure (2007) (dir. Dan Reed)—revenge for attack by gang.

                                                    (72.) Carrie (1976) (dir. Brian de Palma)—revenge of the bullied.

                                                    (73.) Fatal Attraction (1987) (dir. Adrian Lynn)—revenge of the spurned lover; The Coalition (2013) (dir. Monica Mingo)—revenge of four women for being jilted.

                                                    (74.) Cape Fear (1961)—revenge on a lawyer and his family for being a witness at the revenger’s trial; Cape Fear (1991)—revenge on a lawyer and his family for burying documents indicating the victim had a sexual history.

                                                    (75.) Calvary (2013) a parish priest executed for the paedophile acts of fellow priests with which he has no connection in time or place other than his being a Roman Catholic priest.

                                                    (76.) See below at fn xx.

                                                    (77.) 1973 (dir. Clint Eastwood).

                                                    (78.) 2012 (dir. Quentin Tarantino).

                                                    (79.) Portis, C. (1968), True grit (London: Bloomsbury) at 9.

                                                    (80.) The Virgin Spring (1960) (dir. Ingmar Bergman)—revenge of rape and murder of daughter.

                                                    (81.) The Girl with the Dragon Tattoo (2007) (dir. Niels Arden Oplev)—revenge by victim of rape.

                                                    (82.) Les Diaboliques (1955) (dir. Henri-George Clouzot)—revenge on exploiter—to The Bride Wore Black (1968) (dir. Francois Truffaut)—revenge of the five murderers of her husband on their wedding day.

                                                    (83.) Lady Snowblood (1973) (dir. Toshiya Fuijita)—child born in prison avenges the murder of her father by a gang of criminals beyond the reach of the law.

                                                    (84.) The Housemaid (1960) (dir. Ki-young Kim)—see also the Revenge Trilogy of Park Chan-wook (Sympathy for Mr. Vengeance (2002)—revenge for death of daughter, Oldboy (2003)—revenge for unknown actions—and Sympathy for Lady Vengeance (2005)—engineering the death of the child murderer who framed her.

                                                    (85.) 1949 (dir. Robert Hamer).

                                                    (86.) 2015 (dir. Jocelyn Moorhouse).

                                                    (87.) In the Bedroom (2001) (dir. Todd Field) in which a mild small-town couple take the killer of their son and murder him leaving no evidence after finding the legal process compromised; also Tarantino’s Death Proof (2007)—revenge by women on a murderer.

                                                    (88.) Robson, P. (2016), Beyond the courtroom: Vigilantism, revenge and rape-revenge films in the cinema of justice, In C. Picart, M. Jacobsen, & C. Greek (Eds.), Framing law and crime (pp. 165–200) (Lanham, MD: Fairleigh Dickinson University Press)—on which this section draws heavily.

                                                    (89.) Eye for an Eye (1995) (dir. John Schlesinger).

                                                    (90.) Available at (last consulted June 24, 2016).

                                                    (91.) Sperling, Millner, & Warner, (1998), Hollywood be thy name (Roseville, CA: Prima Publishing); Robertson, J. (1989), The hidden cinema: British film censorship in action 1913–1975 (London: Routledge).

                                                    (92.) 1939 (dir. Michael Curtiz).

                                                    (93.) 1953 (dir. George Stevens).

                                                    (95.) Guthrie, W. W. (1940), ibid.

                                                    (96.) Although in the later Denzel Washington (Mathhew Cullen) version an additional personal revenge element is revealed right at the end. The villainous Bartholomow Bogue and his men are responsible for the rape and murder of Cullen’s mother and sisters some years earlier.

                                                    (97.) Greenfield, S., Osborn, G., & Robson, P. (2010), Film and the law (Oxford: Hart).

                                                    (98.) Office for National Statistics 2013.

                                                    (99.) Miller, W. (1998), Clint Eastwood and equity: The virtues of revenge and the shortcomings of law in popular culture, In A. Sarat & T. Kearns (Eds.), Law in the domains of culture (Ann Arbor: University of Michigan Press).

                                                    (100.) Young, A. (2010), The scene of violence (Abingdon, U.K.: Routledge), ch. 3.

                                                    (101.) Young, loc. cit. 44.

                                                    (103.) Young, loc. cit. 66.

                                                    (104.) Young, loc. cit. 73.

                                                    (106.) The earlier Last House on the Left (1972) is on the same lines involving rape and revenge, but by the victim’s parents and is so identified by Read (2000) at 41.

                                                    (107.) Read, J. (2000), The new avengers: feminism, femininity and the rape-revenge cycle (Manchester: Manchester University Press); Heller-Nicholas, A. (2011), Rape-revenge films: A critical study (Jefferson, NC: McFarland); Henry, C. (2014), Revisionist rape-revenge: Redefining a film genre (New York: Palgrave Macmillan); see also Hephaestus Books (2011), Rape and revenge films (Hephaestus Books)—it is a collection of Internet articles.

                                                    (108.) Heller—Nicholas (2011), 172.

                                                    (109.) VideoHound 2008, 467; VideoHound 2005, 513.

                                                    (110.) Henry (2014), 15.

                                                    (111.) Clover, C. (1992), Men, women and chain saws: Gender in the modern horror film (Princeton, NJ: Princeton University Press).

                                                    (112.) Read (2000).

                                                    (113.) Read op. cit. at 8.

                                                    (114.) Read op. cit. at 10.

                                                    (115.) Heller-Nicholas (2011), chs. 2 and 3.

                                                    (116.) Heller—Nicholas loc. cit. ch. 3.

                                                    (117.) Heller-Nicholas loc. cit. ch. 2.

                                                    (118.) Heller-Nicholas loc. cit. at 4.

                                                    (120.) Henry loc. cit. at 22.

                                                    (121.) Henry loc. cit. at 17.

                                                    (122.) Henry loc. cit. at 181.

                                                    (123.) Marital rape and abuse is covered in The Burning Bed (1984) with Farrah Fawcett, Sleeping with the Enemy (1991) with Julia Roberts; and Provoked (2006) with Aishwarya Rai.

                                                    (124.) Turnbull, S. (2016), Border crossings: The transnational career of the television crime drama, In C. Sharp & M. Leiboff (Eds.), Cultural legal studies (London: Routledge).

                                                    (126.) See Nurse, A. (2012), Decoding the dark passenger: The serial killer as a force for justice, Adapting Jeff Lindsay’s Dexter for the small screen, In P. Robson & J. Silbey (Eds.), Law and justice on the small screen (Oxford: Hart).

                                                    (127.) Meditations on Stoic philosophy (170–180) available in Hammond, M. (2006), Meditations (Harmondsworth: Penguin).

                                                    (128.) On revenge (1625), in J. Pitcher (Ed.), The essays (Harmondsworth: Penguin, 1985).

                                                    (129.) Machura (2016), Law and cinema movement, In C. Picart (Ed.), Framing law and crime (New York: Rowman and Littlefield).

                                                    (130.) Podlas, K. (2008), Guilty on all counts: Law and Order’s impact on public perceptions of law and order, Seton Hall Journal of Sports and Entertainment Law, 18, 1–48; Podlas, K. (2009), Impact of television on cross examination and juror “truth.” 14 Widener Law Review, 483.

                                                    (131.) Salzmann, V., & Dunwoody, P. (2005), Prime time lies: Do portrayals of lawyers influence how people think about the legal profession? 58 Southern Methodist University Law Review, 411; Sharp, C. (2005), The ‘Extreme Makeover’ effect of law school: students being transformed by stories. 12 Texas Wesleyan Law Review, 233.

                                                    (132.) Asimow, M., Greenfield, S., Guillermo, J., Machura, S., Osborn, G., Robson, P., Sharp, C. & Sockloskie, R. (2005), Perceptions of lawyers: A transnational study of students views on the image of law and lawyers. 12 International Journal of the Legal Profession, 407.

                                                    (133.) Robson, P., & Schulz, J. (Eds.). (2016), A transnational study of law and justice on TV (Oxford: Hart), covering Australia, Belgium, Canada, Denmark, France, Germany, Greece, Israel, Italy, Poland, Spain, Switzerland, United Kingdom, and the United States.

                                                    (134.) Macaulay, 1987, Images of law in everyday life: The lessons of school, entertainment, and spectator sports, 21 Law & Society Review 185; Friedman 1989, Law, lawyers and popular culture, Yale Law Journal, 98, 1579.

                                                    (135.) Stark S. (1987), Perry Mason meets Sonny Crockett: The history of lawyers and the police as television heroes 42 UMLR 229; Sherwin, R. (2000), Law goes pop: The vanishing line between law and popular culture (Chicago: University of Chicago Press).

                                                    (136.) Robson P., & Silbey, J. (2012), Introduction to law and justice on the small screen (Oxford: Hart), at 9–11.

                                                    (137.) Moran, L, Christie, I., Sandon, E., & Loizidou, E. L. (Eds.), (2004), Law’s moving image (London: Cavendish); A. Sarat, L. Douglas, & M. Umphrey (Eds.), (2005), Law on the screen (Stanford, CA: Stanford University Press).

                                                    (138.) Dailly J., & Davidson, R. (2012), The law of superheroes (New York, Gotham Books); Ramiro Avilés, M., Rivaya, B., & Barranco Avilés, M. (2014), Derechos, Cine, Literatura y Cómics. Cómo y por qué (Valencia, Tirant lo Blanch).