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Introduction
The Delhi High Court delivered an important judgement in Saregama India Limited v. Mr. Ilaiyaraaja [CS(COMM) 143/2026] on February 13, 2026. The case concerned ownership and exploitation of musical works created for films between 1976 and 2001. At its core, the matter raised questions about whether composers retain copyright in works created for films, or whether producers, and by extension their assignees, hold exclusive rights. The Court’s order clarified the scope of Sections 17 and 30 of the Copyright Act, 1957, and highlighted the principle that film producers are the first owners of works commissioned for cinematograph films unless a contract provides otherwise.
Facts of the Case
Saregama, formerly known as The Gramophone Company of India Limited, entered into numerous assignment agreements with film producers between 1976 and 2001. These agreements transferred rights in sound recordings, musical works, and lyrics of approximately 134 films to Saregama. The company claimed that these assignments were irrevocable, worldwide, and perpetual, and that it had continuously exploited the works through licensing and distribution.
On January 13, 2026, Ilaiyaraaja issued a legal notice to Saregama asserting ownership over the musical works he had composed and orchestrated for these films. Shortly thereafter, in February 2026, Saregama discovered that Ilaiyaraaja was uploading these works to platforms such as Amazon Music, iTunes, and JioSaavn, while simultaneously making ownership claims. Screenshots and inlay cards were produced to demonstrate infringement.
This was not the first dispute between the parties. A judgment dated January 30, 2025, from a Co‑ordinate Bench of the Delhi High Court had already addressed similar issues. That decision was under appeal before a Division Bench, which reserved judgment on February 12, 2026. Importantly, no stay was granted, allowing Saregama to pursue the present injunction.
Argument in Favour
Saregama argued that the film producers were the first owners of the works under copyright law, as they had engaged composers and lyricists to create works for incorporation into cinematograph films. These producers had then assigned their rights irrevocably to Saregama, giving the company exclusive control.
The plaintiff relied on Section 30 of the Copyright Act, 1957, which grants the copyright owner the exclusive right to license works. It contended that only Saregama could grant licenses to third parties.
Saregama also invoked Section 17(b) and (c) of the Act. These provisions establish that when a composer creates music at the instance of a film producer for valuable consideration, the producer becomes the first owner of the copyright. Unless a contract to the contrary exists, composers cannot claim independent rights.
To support its case, Saregama cited several precedents. In Indian Performing Right Society Ltd. v. Eastern Indian Motion Pictures Association (1977) 2 SCC 820, the Supreme Court held that film producers are the first owners of works incorporated into films, and composers or lyricists do not retain separate copyright unless expressly contracted. Paragraph 17 of that judgment was particularly emphasized. The Court in that case also referred to Wallerstein v. Herbert (1867) 16 LTR 453, which held that music composed for a drama was merely an accessory to the main work and did not constitute an independent copyright.
Saregama further relied on Yamini Manohar v. T.K.D. Keerthi (2024) 5 SCC 815, where the Supreme Court held that exemption from mandatory pre‑litigation mediation under Section 12A of the Commercial Courts Act can be granted when urgent interim relief is sought. This precedent was invoked to justify bypassing mediation in the present case.
Court’s Decision
The Delhi High Court granted an ex‑parte ad‑interim injunction in favor of Saregama.
The Court found that Saregama had produced assignment agreements and inlay cards showing long‑standing exploitation of the works. This established a strong prima facie case of ownership. The Court held that the balance of convenience lay with Saregama, which had been commercially exploiting the works for decades. Allowing Ilaiyaraaja to continue licensing would cause confusion and undermine Saregama’s rights.
The Court emphasized that unauthorized exploitation by Ilaiyaraaja could not be adequately compensated in monetary terms. Irreparable injury would result if injunction was not granted.
In reaching its decision, the Court applied Section 17(b) and (c) of the Copyright Act, confirming that producers are first owners when works are commissioned for films. Section 30 reinforced Saregama’s exclusive right to license works. Section 12A of the Commercial Courts Act was also applied, with exemption from pre‑institution mediation granted due to urgency, citing Yamini Manohar.
The Court relied heavily on Indian Performing Right Society Ltd. (1977) 2 SCC 820, which provided the foundational principle that film producers defeat composer rights unless a contrary contract exists. Wallerstein v. Herbert (1867) 16 LTR 453 was cited to support the view that music for films is an accessory to the main work. Yamini Manohar (2024) 5 SCC 815 was cited to justify bypassing mediation for urgent injunctions.
The Court restrained Ilaiyaraaja, his agents, and representatives from exploiting, licensing, or making ownership claims over the works listed in the suit. Summons were issued, requiring Ilaiyaraaja to file a written statement within 30 days. The matter was listed for further hearing in April 2026.
Conclusion
The Delhi High Court’s ruling in Saregama India Limited v. Ilaiyaraaja reinforces the principle that film producers are the first owners of works created for films, unless a contract explicitly preserves rights for composers or lyricists. By granting an injunction, the Court reaffirmed the strength of assignment agreements and the statutory framework under Sections 17 and 30 of the Copyright Act.
This case is significant because it involves a celebrated composer asserting moral and creative claims against a corporate entity with contractual rights. The Court’s reliance on precedents such as Indian Performing Right Society Ltd. and Wallerstein v. Herbert demonstrates continuity in judicial interpretation: music created for films is inseparable from the film itself, and ownership vests in the producer unless otherwise agreed.
The decision also highlights the importance of urgent judicial intervention in intellectual property disputes, where unauthorized exploitation can cause irreparable harm. By exempting the matter from pre‑litigation mediation under Section 12A of the Commercial Courts Act, the Court recognized the immediacy of protecting copyright holders.
Ultimately, the ruling strengthens the position of copyright assignees like Saregama, ensuring that decades‑old agreements remain enforceable against even the most prominent creators. It serves as a reminder that while artistic contributions are invaluable, the law prioritizes contractual certainty and statutory ownership rules to maintain order in the creative industries.
