For me it would Manisha Koirala and Shilpa Shetty. They both are brilliant actresses, and yet never got the fame they deserved. I loved Manisha's acting in Khamoshi and Dil Se, and I feel she deserved the award for best actress more than Karishma and Aishwarya. And I loved Shilpa in Phir Milenge.
From actors, no one actually. Whoever had talent had ruled so far, IMHO.
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