Composer vs Copyright Owner: Delhi High Court Grants Interim Relief to Saregama in Ilaiyaraaja Dispute – CS(COMM) 143/2026

Summary

In a recent copyright dispute before the Delhi High Court, Saregama India Limited sought urgent injunctive relief against renowned music composer Ilaiyaraaja for allegedly exploiting musical works over which Saregama claimed copyright ownership.

The dispute centered on whether the composer could independently license musical works that formed part of cinematograph films whose rights had allegedly been assigned to Saregama by film producers. At the interim stage, the Court found that Saregama had established a prima facie case of ownership through assignment agreements and granted an ex parte ad-interim injunction, restraining the defendant from exploiting or licensing the works listed in the plaint.

Facts of the Case

Saregama India Limited filed a commercial suit asserting that between 1976 and 2001 it had entered into assignment agreements with producers of several cinematograph films. Through these agreements, the producers allegedly transferred to Saregama the copyright in the sound recordings as well as the underlying musical and literary works forming part of those films. Saregama contended that these assignments conferred exclusive, worldwide and perpetual rights over the concerned works.

In February 2026, Saregama claimed to have discovered that Mr. Ilaiyaraaja was uploading and licensing these works on various digital streaming platforms such as Amazon Music, Apple iTunes and JioSaavn while asserting ownership over them. According to the plaintiff, such actions amounted to copyright infringement and false assertion of proprietary rights.

To support its claim, Saregama relied on assignment agreements executed with film producers, inlay cards from the films, and previous court orders indicating that it was the lawful owner of the copyright in the relevant works.

Issues

1. Whether Saregama had demonstrated a prima facie case of ownership over the copyrighted works.
2. Whether a composer such as Mr. Ilaiyaraaja could claim independent copyright in the works despite the rights of the film producer.
3. Whether the circumstances justified the grant of an ex parte ad-interim injunction.

Analysis of the Court

The Court first examined whether the plaintiff had established ownership of the works in question. It observed that Saregama had placed assignment agreements on record demonstrating that the film producers had assigned copyright in the sound recordings and related works to it. Since producers are generally regarded as the first owners of copyright in cinematograph films under the statutory scheme, such assignments supported the plaintiff’s claim of ownership.

While examining the composer’s rights, the Court referred to the decision of the Supreme Court of India in Indian Performing Right Society Ltd. v. Eastern Indian Motion Pictures Association (1977) 2 SCC 820. In that case,  the Supreme Court had clarified that when a composer creates music for a film for consideration, the film producer ordinarily becomes the first owner of the copyright unless there exists a contract to the contrary. On this basis, the Court observed that Saregama’s claim derived from the producers had prima facie legal support.

The Court then applied the three well-established tests governing interim injunctions: existence of a prima facie case, balance of convenience, and irreparable harm. It found that Saregama had produced sufficient documentary evidence to demonstrate a strong prima facie case. The balance of convenience also favored the plaintiff, as continued exploitation of the works by the defendant could interfere with existing licensing arrangements and adversely affect Saregama’s commercial interests. The Court further held that such harm could not be adequately compensated through monetary damages, particularly where competing claims of ownership were being publicly asserted.

The Court also granted exemption from pre-institution mediation under Section 12A of the Commercial Courts Act, noting that urgent interim relief had been sought and relying on precedent permitting such exemption in appropriate cases.

Decision of the Case

The Delhi High Court granted an ex parte ad-interim injunction restraining Mr. Ilaiyaraaja and all persons acting on his behalf from exploiting, licensing, or claiming ownership over the copyrighted works listed in the plaint. The defendant was directed to file a reply within four weeks. The Court also ordered issuance of summons and passed procedural directions regarding pleadings and filing of documents, while clarifying that its observations were prima facie and confined to the interim stage of the proceedings.

Conclusion

The decision highlights the continued relevance of the principle that film producers are ordinarily the first owners of copyright in cinematograph works, unless a contract provides otherwise. It also highlights the importance of assignment agreements in determining ownership of sound recordings and related works, particularly in disputes involving legacy music catalogues and digital distribution platforms.

As the case proceeds to trial, it is likely to contribute further to the evolving jurisprudence on copyright ownership in the film and music industry, especially in the context of streaming platforms and the commercialization of older musical works.