The Delhi High Court on Wednesday refused to vacate the interim injunction granted in favour of Saregama India Limited in its ongoing dispute with veteran music composer Ilaiyaraaja over copyright in sound recordings and the underlying literary and musical works forming part of 134 cinematograph films.
The single-judge Bench of Justice Tushar Rao Gedela declined to interfere with the earlier ex parte ad interim injunction restraining Ilaiyaraaja from exploiting, commercially using, communicating to the public, issuing licences, assigning rights or claiming ownership over the disputed copyrighted works pending adjudication of the suit.
The injunction covers sound recordings as well as the underlying literary and musical works in several iconic films, including Annakkili, 16 Vayathiniley, Kavikkuyil, Bharathi, Pallavi Anu Pallavi, Mullum Malarum, Raaja Paarvai, Netrikkann, Kalyanaraman, Nizhalgal and Moodu. A detailed copy of the order is awaited.
The dispute arises from a copyright infringement suit instituted by Saregama alleging that Ilaiyaraaja had been commercially exploiting and licensing works over which the company claims exclusive copyright ownership.
On February 13, 2026, the High Court had granted an ex parte ad interim injunction restraining the composer and persons acting on his behalf from exploiting, licensing or asserting ownership over Saregama’s copyrighted repertoire comprising sound recordings and the underlying literary and musical works relating to 134 films.
Saregama submitted that it was incorporated in 1901 as The Gramophone Company of India Limited and was subsequently renamed Saregama India Limited. It contended that between 1976 and 2001, it entered into valid copyright assignment agreements with producers of several cinematograph films, under which the copyright in the sound recordings and the underlying literary and musical works stood assigned to the company.
The company further informed the Court that it owns one of India’s largest catalogues of film and non-film music across Tamil, Hindi, Malayalam, Kannada, Telugu and several other languages, and regularly licenses these works to broadcasters, digital streaming platforms and other commercial entities.
According to Saregama, during the first week of February 2026 it discovered alleged unauthorised commercial exploitation of its copyrighted works on digital platforms including Amazon Music, Apple iTunes and JioSaavn. It also alleged that Ilaiyaraaja had asserted proprietary rights and ownership claims over those works despite the copyrights having been assigned to Saregama.
The company also relied upon a legal notice issued by Ilaiyaraaja on January 13, 2026, wherein he claimed ownership over musical works composed, arranged and orchestrated by him for various films, including works forming part of the present suit.
Placing reliance on Section 17(b) of the Copyright Act, 1957, Saregama argued that where a producer commissions a composer to create music for a cinematograph film for valuable consideration, the producer becomes the first owner of copyright in those musical works unless there is a contract to the contrary. It submitted that those copyrights were subsequently assigned to Saregama through valid assignment deeds, making it the present copyright proprietor.
While granting interim relief in February, the High Court had recorded a prima facie finding that Saregama had established a strong case in its favour. It further held that the balance of convenience lay with the company and that denial of interim protection would result in irreparable loss and injury owing to continued unauthorised commercial exploitation of the copyrighted works.
The Court had also relied on the Supreme Court’s landmark judgment in Indian Performing Right Society Ltd. v. Eastern Indian Motion Pictures Association (1977), wherein it was held that a music composer or lyricist commissioned by a film producer does not retain independent copyright in works created for a cinematograph film unless an express contractual stipulation provides otherwise.
Consequently, the Court had restrained Ilaiyaraaja and all persons acting on his behalf from exploiting, assigning, licensing or making ownership claims before third parties in respect of the disputed sound recordings and the underlying literary and musical works.
Ilaiyaraaja subsequently moved the High Court seeking vacation of the interim injunction. However, after hearing the parties, the Court declined to vacate the interim protection and allowed the injunction granted in favour of Saregama to continue pending disposal of the copyright suit.
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