In the crime film there is a distinction between "bad" persons (criminals, enemy agents, terrorists, etc.) and "good" persons (police officers, secret agents, etc.) who defend democracy and common values (as they are interpreted by the authors). The center there is the minimum of personal reasons. Circumstances (sometimes far-fetched) often force the positive hero to curb a chief scoundrel by him/herself instead of calling for reinforcement as the law and the job descriptions require. :)
Plots in the genre of "bad girls" and "women in prison" emphasize on personal reasons of characters. There is little unambiguity as far as "bad vs. good" is concerned. Often, in "Women in prison" movies, a female protagonist is an innocent victim, attempting to survive. She usually don't participate in contentions being more often a whipping girl. Serious brawls occur between local tough girls and it's difficult to determine who is good and who is bad. The exception is represented by the movies where a covert woman takes root into the prisoner society.
An "Action movie" is a loose concept but the most important component of these films is "action", in particular violence (in this context, women's violence). In past years, with spreading of oriental martial arts, more and more action movies appeared containing women's combative scenes with usage of manifold fighting techniques (with weapon and without it).
An Action Movie is a genre in movies which involves excessive fighting and stunts, normally in close-quarters, as compared to wars. The genre, although popular since the 1950s, became one of the most dominant forms in Hollywood in the 1980s and 1990s. Recently, with tremendous achievements in the computer graphics, special effects are widely adopted in the scenes of violence and action. Current trends in action film include a development toward more elaborate fight scenes, perhaps because of the success of Asian martial arts elements, such as kung fu and karate. Actors in action movies are now much more skilled in the art and aesthetic of fighting than they have been in the past.
Popularity of the action movies attracts attention of feminists who noticed that the separation was very clear in most such films between the physical male who controls the scene and the look and the female, who is almost always the object of the look. Until recently, the most of female characters in the action film are still portrayed as incompetent and lacking in good judgement. These characters tend to unintentionally make life harder for the hero. Although female characters in most action films are nothing more than objects, a sweet prize for the winner, hostages, loving wives and the like, there has been a move towards stronger female characters.
The science-fiction action movie ALIEN (1979) by Ridley Scott and its continuation ALIENS (1986) by James Cameron probably happened to be the first action movies to feature a strong female protagonist, independent of a guiding male lead (Sigourney Weaver). This is true as far as mainstream film with is considered with real characters and emotions - of course, entertaining odd jobs with "Bruce Lees" in skirts appeared long before (for instance, in the TV serial телесериале CHARLIE'S ANGELS (1976 - 1981).
The Weaver's character impulsed the Girl Power phenomenon that emerged in Hollywood towards the early 2000s when more and more action-movies with powerful female leads appeared.
Perhaps, the most typical example of an action film with strong women and women's combat is the outstanding (and controversial) movie KILL BILL 1,2 (2003, 2004) by Quentin Tarantino. Fascinating Uma Thurman surpassed herself in arts of fighting, suffice it to say that she fought with knifes against Vivica Fox, against Chiaki Kuriama (Samurai sword against a spiked ball; by the way, Kuriama just "came" from BATORU ROWAIARU (2000) in her school uniform), against Lucy Liu with Samurai swords (exceptionally spectacular battle in a winter Japanese garden) and against Daryl Hannah(partly hand-to-hand, partly with swords. In fact, Uma Turman has finished off a lot of people there... something close to a hundred...
In fact, martial arts are used in the most of fights in the action film (mostly Kung-Fu). Hong-Kong studios produce a lot of such movies. Tireless Jackie Chan, who works in the mock style seems to be the king of this genre. His arch look and terrible English slightly compensate the primitiveness of the combative scenes and vacancy of the plots, diluting them with cheap humor. Of course, combative women appear here too - in the movie, ARMOUR OF GOD or LONG XIONG HU DI (1987) Chan fights concurrently against four "beautiful" Amazons.
Bad girl movies are a subcategory of "film noir") (black film) labeled by latter-day movie buffs to describe the dark films of the 1940s and 1950s starring beautiful women who were usually on the wrong side of the law. The movie posters to these films usually featured sexy artwork of the lady in question, posed seductively, and these images today in original posters and reproductions are as collected today, as are the films themselves are on VHS and DVD.
Who fights above all beyond athletic venues? Certainly, the "bad girls". Who are the bad girls after all? Hooligans having antisocial behavior who pick a fight with each other and peaceful citizens. Prostitutes alienated out of the society. Various female criminals or just women temporarily being off the beam...
In the movie ANGEL 4: UNDERCOVER (1993) a "bad girl", jealous fan of a famous rock star (quite unequable bozo, a little reminding John Bon Jovi), kills potential rivals while a female officer of the law machinery investigates the case. After all, the women are engaged in a fight but the beautiful agent appears much tougher, so the fight is a mismatch and looks not exciting.
Fighting between Teri Hatcher and Charlize Theron from the movie TWO DAYS IN THE VALLEY (1996) by John Herzfeld became a part of the Amazon's best catfighting scenes. The girls with model appearance are fighting toughly and skillfully like men. What else attracts in this scene? Probably, its absolute meaningless... You barely can seriously consider it as a fight over the dead body of the man killed by themselves. They simply are in bad mood and they don't like each other too much... In short, contemporary women are on edge. Unfortunately, James Bond didn't stick around and everything finished tragically for the one of the participants. It's quite typical for a comedy of absurd, which the movie really is. :)
The most of plots in the film of crimes (for instance, "a good girl fights against a bad girl") are rather primitive and trite. However, some women's fights are staged quite well. In the very end of the boring movie BALLISTIC (1995), a spectacular female fight occurs all the sudden. Ballistic, a dark-skinned female police officer Marjean Holdentakes root in a criminal gang. She is disclosed and forced to fight against a mighty girl (muscular Cory Everson), a girl-friend of a head scoundrel and his guard. The fight is very well choreographed, even though it's not too much realistic. As always, the "good girl" (more cunning and lissom Holden) defeats the "bad girl" (looking stronger Everson).
As it was said, oriental martial art techniques are demonstrated in the most fights shown in the modern movies. Just one example: a fight between two girls in an underground tube in the movie BULLETPROOF MONK (2003). The girls (Jaime King and Victoria Smurfit) fight to death brutally and dynamically (and the choreography do not depress too much.) As usual, the good one wins. :)
There is a well-known scene of a girlfight on a limousine backseat from the film TRUE LIES (1994) with Schwarzenegger. Jamie Lee Curtis is a secret agent and Tia Carrere is a terrorist. The scene is short and there is nothing exciting, except the "sensual cadre" in which Jamie slowly squashes Tia away by the bare feet.
Perhaps the ultimate bad girl movies are "women in prison" films (WIP); the majority of which were made well after the classical "film noir" period and include one of the more socially-conscious films of the genre, WHY MUST I DIE? (1960).
The WIP genre is a beneficial area for the female combat fans - many women tied together inclining to violence - in prison they live according specific rules and hierarchy. The mentioned Barbara "The Doctor" expressed a few interesting thoughts regarding this genre: "Among the most popular subjects of latter 20th century catfight art, the female prisoner, straddles the line between the "empowered" wild woman and woman under control. In the mega sense, these women are "controlled": they are in prison, after all. In the narrower sense, however, they are members of a females-only society, which, in the fantasy, replicates the violence, hierarchical politics and forced sexuality of male institutions (and male fantasies, by the way). Prisons are real, of course, but don't confuse a real prison with this stuff! Glorified by libraries of B movies, these women are gorgeous, voluptuous, scantily clad, strutting packages of volcanic sexuality and they're always looking for a fight. They fight over turf, over words, over "stuff" and, quite often, over other women and they fight in the way you get the erotic message. A typical example: HOUSE OF WOMEN (1962) contains plenty of catfights. The prisoner woman is a wild woman anointed as such by our society: she broke the law, she engaged in criminal behavior, she's wild as hell and, in this fantasy, we are cast into the role of voyeurs, peeking behind the forbidden walls into a forbidden enclave. It's the taboo, as much as the action, that provides the enrichment of this fantasy.
WIP films are a subgenre of exploitation film (that typically sacrifice traditional notions of artistic merit for the sensational display of some topic about which the audience may be curious, or have some prurient interest, especially sex, gore, and violence.). Their stories feature imprisoned women who are subjected to sexual and physical abuse, typically by sadistic female prison wardens and (sometimes) by other inmates.
Hollywood made movies set in women's prisons as early as the 1930's such as HOLD YOUR MAN (1933) with Jean Harlow but generally only a small part of the action took place inside the prison. It was not until the 1950's with the 1950 release CAGED, 1950) starring Eleanor Parker and Agnes Moorehead, WOMEN'S PRISON (1955) with Ida Lupino and Cleo Moore as well as BETRAYED WOMEN (1955). The whole storyline (sparkling with catfights) of those films was set in correctional facilities.
The most well-known examples of the women in prison film are perhaps ILSA, SHE WOLF OF THE SS (1975) by Don Edmonds and Jonathan Demme's CAGED HEAT (1974). Actress Pam Grier (famous by the 1973 movies ARENA and COFFY) starred in a number of films in the genre, such as THE BIG DOLL HOUSE (1971), THE BIG BIRD CAGE (1972) and WOMEN IN CAGES (1971).
Women in prison films developed in the 1930s as melodramas. Young heroines were shown the way to a righteous life by way of the prison. Under the influence of pulp magazines and paperbacks, they became popular B-movies in the 1950s. Since the 1970s they are a specialty product of pornography. Women in prison films have more to do with male heterosexual fantasies than real prison life (female combat is its component.) The lesbian theme in these films also influenced mainstream cinema in films as CHICAGO, 2002).
European cinema too had its share of the genre with titles like a href="http://en.wikipedia.org/w/index.php?title=Frauengef%C3%A4ngnis&action=edit" target=new>FRAUENGEFANGNIS (Women's Prion or Barbed Wire Dolls, 1975) and a href="http://www.imdb.com/title/tt0063977/" target=new>99 MUJERES (99 WOMEN, 1969) by a href="http://en.wikipedia.org/wiki/Jesus_Franco" target=new>Jesus Franco.
This genre is so well developed that some actresses (like above mentioned Pam Grier) specialize in such roles. In the typical for the genre movie, THE BIG DOLL HOUSE (1971) a group of women prisoners working at a corn plantation steps aside in order to let two of them "sort out their relationship" physically. One of the fighters (Pam Grier) plays a bad girl. The bout continues in a big dirty puddle where the pugnacious girls find themselves in process of the argument. The Pam's opponent wins (a good girl!  ). The fight is staged very showily, some kind of a duel. The other women do not interfere playing seconds.
Basically, some of these films are more remembered by their catfights rather than their quality. Even quite bad movies sometimes have well presented female fights. One of the movies is undeservedly well-known - REFORM SCHOOL GIRLS (1986). One of three catfights should be noted - a brief good fight between a head bad girl and a black prison inmate.
Another plot of fighting between white and black girls occurs in the movie BLACK MAMA, WHITE MAMA (1972). When two troublemaking female prisoners (one a revolutionary, the other a former harem-girl) can't seem to get along, they are chained together and extradited for safekeeping. The women, still chained together, stumble, stab, and catfight their way across the wilderness, igniting a bloody shootout between gangsters and a group of revolutionaries. Perhaps, the subject of a fight between female captives fastened together became a prototype of the famous slave fight in the THE SEVEN MAGNIFICENT GLADIATORS (1983), even though that fight is much more sensual.
The typical movie about a "stranger" in a women's prison is 99 WOMEN (1979) by Jesus Franco. The film follows a familiar pattern. A group of girls are brought to an inescapable fortress/prison were they are to serve out their sentence. Inspector Leonie Carol (Maria Schell) is sent to underground assess the staff and the condition of the inmates. After all, Schell and her inmate are involved in a "tag-team" fight against another pair - the facilities cruel head matron (Mercedes McCambridge) and the prison's on-site governor (Herbert Lom).
As it is in any mass culture area, the vast majority of "bad girl"/WIP films are not shine by high quality. In order to see how bad a typical film in this genre might be, read a brief description of the movie BAD GIRLS DORMITORY (1985) from "the Encyclopedia of women in prison films": "Carey Zuris stars as a rape victim/boyfriend killer thrown to the wolves at a juvenile detention facility. This low budget tacky film has all the right elements. Bad catfights, 4 shower scenes, lesbians, drugs, incest, gang bangs, rapes, kung fu, suicide, murder, and tons of nudity." 
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I guess they shot that one separately but didn't have a substitute shot so they used it -- it's not noticeable in the video action but, in vidcaps, the gaff is revealed! Still, a brilliant piece of television!
