The Delhi High Court has granted an ex-parte ad-interim injunction in favour of Saregama India Limited, restraining noted music composer Ilaiyaraaja from exploiting, licensing, or claiming ownership over a large catalogue of sound recordings and musical and literary works forming part of several cinematograph films.
Justice Tushar Rao Gedela passed the order on February 13, 2026, in a commercial suit filed by Saregama alleging copyright infringement. The Court exempted the plaintiff from mandatory pre-institution mediation under Section 12A of the Commercial Courts Act, noting the urgency of interim relief, and allowed various procedural applications, including filing of additional documents and deferred payment of court fees.
Saregama asserted that it is the owner of copyright in the sound recordings and underlying musical and literary works of numerous films by virtue of assignment agreements executed between 1976 and 2001 with original film producers. It contended that these rights are absolute, worldwide, and perpetual, and that it alone is entitled to license the works under the Copyright Act, 1957.
The company alleged that in early February 2026, Ilaiyaraaja had unauthorisedly uploaded the disputed works on digital platforms such as Amazon Music, iTunes and JioSaavn, while also making ownership claims and issuing licences to third parties, despite lacking copyright title. It was further alleged that the defendant had issued a baseless legal notice asserting ownership over the musical works composed by him for the films in question.
Relying on Section 17(b) and (c) of the Copyright Act and the Supreme Court’s ruling in Indian Performing Right Society Ltd. v. Eastern Indian Motion Pictures Association, the Court noted that, in the absence of a contract to the contrary, the producer of a cinematograph film is the first owner of copyright in works created for the film, and such rights can be validly assigned.
On a prima facie assessment of the assignment agreements, inlay cards, and instances of alleged infringement, the Court held that Saregama had made out a strong case. It found that the balance of convenience lay in favour of the plaintiff and that irreparable harm would be caused if interim protection were denied.
Accordingly, the Court restrained Ilaiyaraaja and all persons acting on his behalf from exploiting, licensing, or asserting ownership over the copyrighted works listed in Annexure-A to the order. The defendant has been directed to file a reply within four weeks. The matter will be taken up next on April 2, 2026.
Appearances:
For the Plaintiff: Mr. Chander M. Lall, Senior Advocate alongwith Mr. Ankur Sangal, Mr. Ankit Arvind, Mr. Shashwat Rakshit, Mr. Rishabh Rao and Ms. Annanya Mehan, Advocates.
For the Defendant: None.
