Question: Which film has the director died later, Too Tough To Kill or Jhoothi?

Context paragraphs:
title: Jhoothi
paragraph_text: Jhoothi is a 1985 Bollywood Hindi comedy film directed by Hrishikesh Mukherjee. The film stars Rekha, Raj Babbar, Amol Palekar, Supriya Pathak and Deven Verma in the lead roles.
title: Kill or Be Killed (1980 film)
paragraph_text: Kill or Be Killed( released as Karate Olympiad in South Africa) is a 1977 South African/ American martial arts film directed by Ivan Hall. Shot in South Africa, the film was titled" Kill or Be Killed" in the United States in 1980 to capitalize on the popularity of American martial arts films.
title: Too Tough to Care
paragraph_text: Too Tough to Care is an 18- minute educational film produced in 1964 to undermine teenage resistance to anti-smoking education. Unlike other films in its genre," Too Tough to Care" used satire and humor to illustrate the misleading claims of cigarette advertising. The film garnered attention in both the mainstream press as well as academic journals.
title: D. Ross Lederman
paragraph_text: David Ross Lederman (December 12, 1894 – August 24, 1972) was an American film director noted for his Western/action/adventure films of the 1930s and 1940s. Starting out as an extra in Mack Sennett's Keystone Cops series, Lederman worked his way through the ranks of film production, and first made his mark as a second-unit director. He directed several B-Western serials in the early 1930s, such as "Two-Fisted Law" and "Texas Cyclone" both 1932, in which he worked with Tim McCoy and a young John Wayne. Becoming a full feature director in the late 1930s, Lederman specialized in action films and especially westerns, continuing to produce films with McCoy at Columbia Pictures.
title: Too Tough to Kill
paragraph_text: Too Tough to Kill is a 1935 American drama film directed by D. Ross Lederman and starring Victor Jory.
title: Tough to Handle
paragraph_text: Tough to Handle is a 1937 American film directed by S. Roy Luby.
title: Tough to Kill
paragraph_text: Tough to Kill is a 1978 Italian action film shot in the Dominican Republic written and directed by Joe D'Amato and starring Luc Merenda and Donald O'Brien.
title: Kill or Be Killed (1966 film)
paragraph_text: Kill or Be Killed( also known as" Ringo Against Johnny Colt" and" Kill or Die") is a 1966 Italian Spaghetti Western film directed by Tanio Boccia.
title: A Cause to Kill
paragraph_text: A Cause to Kill or Sha Ji is a 1970 Hong Kong Shaw Brothers thriller film directed by Murayama Mitsuo.
title: Hrishikesh Mukherjee
paragraph_text: Hrishikesh Mukherjee( 30 September 1922 – 27 August 2006) was an Indian film director, editor and writer regarded as one of the greatest filmmakers of Indian cinema, known for a number of films, including Anari," Satyakam Chupke ChupkeAnupamaAnandAbhimaanGuddiGol MaalMajhli DidiChaitaliAashirwadBawarchiKissi Se Na Kehna", and" Namak Haraam." Popularly known as" Hrishi- da", he directed 42 films during his career spanning over four decades, and is named the pioneer of the' middle cinema' of India. Renowned for his social films that reflected the changing middle- class ethos, Mukherjee" carved a middle path between the extravagance of mainstream cinema and the stark realism of art cinema". He also remained the chairman of the Central Board of Film Certification( CBFC) and of the National Film Development Corporation( NFDC). The Government of India honoured him with the Dada Saheb Phalke Award in 1999 and the Padma Vibhushan in 2001. He received the NTR National Award in 2001 and he also won eight Filmfare Awards.

Reasoning steps:
Too Tough to Kill director D. Ross Lederman
Jhoothi director Hrishikesh Mukherjee
D. Ross Lederman date of death August 24, 1972
Hrishikesh Mukherjee date of death 27 August 2006

Answer: spans: Jhoothi