Rockstar’s Manhunt 2 was submitted to the BBFC on both the PlayStation 2 and Nintendo Wii console formats in 2007.  This game has an interesting and complex classification history, as it was originally rejected by the BBFC and went through several levels of appeal hearings before it was finally granted an 18 classification certificate in March 2008.

Manhunt 2 is a violent action game with a psychological-horror theme. The player takes on the role of Daniel Lamb, a seemingly disturbed patient in a mental facility, who escapes from the institution in an effort to discover who he really is. As he progresses through various environments, collecting clues and information about his identity, he is confronted by numerous thugs employed by 'The Project' - a secretive experimental organisation, whom he must either evade or kill in order to ensure his own survival.

In order to successfully kill his targets, the player-character Daniel must commit acts of strong and - felt BBFC examiners - sadistic violence, often in the form of stealth executions by creeping up behind his victims and despatching them before he is discovered.  A range of weapons and everyday items are used to perform these killings, including syringes, glass shards, pens, crowbars, spades, power-saws, clubs, baseball bats, axes, pliers and, later on in the game, firearms.  Each killing is graphically portrayed as a brief video scene where weapons are seen to impact on various parts of the victim's body, accompanied byrealistic sound effects and blood spurts.

The cumulative effect of these killings creates a very strong impression of almost continuous violence and horror, and this led the BBFC to reject the game in June 2007, a very serious and rare action.  The Board felt that Manhunt 2 was: 'Distinguishable from recent high-end video games by its unremitting bleakness and callousness of tone in an overall game context which constantly encourages visceral killing with exceptionally little alleviation or distancing. There is sustained and cumulative casual sadism in the way in which these killings are committed, and encouraged, in the game'. 

Although the original Manhunt game had been passed 18 uncut in 2003, the BBFC argued that it 'was already at the very top end of what the Board judged to be acceptable at that category' and that Manhunt 2 was notably different, mentioning its 'unrelenting focus on stalking and brutal slaying and the sheer lack of alternative pleasures on offer to the gamer, together with the different overall narrative context'.

Considering Manhunt 2 in relation to the Video Recordings Act, the BBFC’s view was that the game would present 'a range of unjustifiable harm risks to both minors and adults' and so denied it a certificate.

A revised version of Manhunt 2 was then submitted to the BBFC.  The BBFC felt that the changes made to the game did not go far enough to address the origninal concerns and as a result, the BBFC rejected this revised version of the game in October 2007.

Under the terms of the Video Recordings Act, the game’s distributor, Rockstar, had the right to appeal the BBFC’s decision.  In December 2007, the Video Appeals Committee (VAC) upheld Rockstar’s appeal against the BBFC’s rejection of the modified version of Manhunt 2, with the VAC deciding four votes to three in favour of Rockstar.

After receiving and considering the VAC’s Judgement, the BBFC applied for a judicial review of the VAC’s decision to overturn the BBFC’s rejection of Manhunt 2.  This was because in the BBFC’s view: 'the VAC Judgement was based on an approach to harm which is an incorrect interpretation of the Video Recordings Act. The VAC judgement, if allowed to stand, would have fundamental implications with regard to all the Board’s decisions, including those turning upon questions of unacceptable levels of violence'.

The case went to Judicial Review before the High Court, which quashed the VAC’s decision to overturn the BBFC’s rejection of Manhunt 2 on grounds of errors of law.

Following this, the VAC reconsidered Rockstar’s appeal in March 2008, in light of the High Court’s directions on the law.  It decided however, again by a majority of four to three, to allow the appeal on the basis that the modified version of Manhunt 2 should be given an 18 certificate.

The BBFC then issued an 18 certificate, following legal advice that there was no realistic basis for a further challenge to the VAC’s decision.  As the BBFC’s Director, David Cooke, said at the time:

'We never take rejection decisions lightly, and they always involve a complex balance of considerations. We twice rejected Manhunt 2, and then pursued a judicial review challenge, because we considered, after exceptionally thorough examination, that it posed a real potential harm risk. However, the Video Appeals Committee has again exercised its independent scrutiny. It is now clear, in the light of this decision, and our legal advice, that we have no alternative but to issue an 18 certificate to the game.'

The 18 certificate was issued along with BBFCinsight stating that Manhunt 2 contained ‘very strong bloody and sadistic violence’. The more expanded version of the BBFCinsight emphasised that the game’s cumulative impression of strong violence and horror was too strong to be contained at any category lower than 18 and that the game is entirely unsuitable for anyone below this age.

The original version of the game remains rejected by the BBFC and has never been granted a classification.  The VAC Appeal and subsequent 18 certificate relate only to the second, revised, version.