Composer Cannot License Lyrics or Sound Recordings Owned by Producers: Delhi HC

The Delhi High Court, in Mr. Ilaiyaraaja v. Saregama India Limited, delineated the boundaries of copyright between music composers and film producers, clarifying that while a composer retains rights over the “musical work,” they cannot validly license the underlying lyrics or the final sound recording without the producer’s authorization.

A division bench of Justice C. Hari Shankar and Justice Om Prakash Shukla delivered this ruling while hearing an appeal filed by the renowned composer against an interim injunction that restrained the use of a recreated version of the iconic song "En Iniya Pon Nilave" in a new film. The dispute brought to the fore the complex interplay between the rights of authors of underlying works and the owners of cinematograph films under the Copyright Act, 1957.

The Intersection of Musical Works and Cinematograph Films

Summarizing the core legal conflict, the Court examined how a song, once integrated into a film, operates under dual layers of protection. While the composer is the 'author' of the musical work, the producer is the author of the 'sound recording' and the 'cinematograph film' itself.

The Court, in its reasoning, observed: "By operation of Section 13(4), the copyright, if any, held by RCA and, later, by SIL, in the sound recording relating to the musical work contained in the disputed song cannot derogate from, or affect, the separate copyright held by Ilaiyaraaja in the musical work contained in the disputed song. Ilaiyaraaja’s copyright in the musical work contained in the disputed song, therefore, continues to remain protected and, consequently, his right to exploit the musical work in the manner envisaged by Section 14(a)(iv) and 14(a)(v) read with 14(a)(vi), also remains inviolate and sacrosanct. This right was, however, necessarily limited to the musical component of the disputed song, i.e., the music therein, of which Ilaiyaraaja was the composer. It did not extend to the lyrical component of, or the sound recording in, the disputed song."

Validity of Licensing Agreements and Infringement

The Court noted that the appellant had entered into an agreement with a third-party film company, representing himself as the owner of the sound recording and the underlying works. However, the Court found that the original producer (RCA) had already assigned the sound recording rights to the respondent (Saregama) via a 1980 agreement. Consequently, the composer had no legal standing to license the lyrics (owned by the lyricist) or the original sound recording (owned by the assignee of the producer).

Background:

The dispute arose when Saregama India Limited (SIL) filed a suit alleging infringement of its copyright in the song "En Iniya Pon Nilave" from the film 'Moodu Pani'. SIL claimed that the defendants had recreated the song for an upcoming film 'Aghathiyaa' based on a license granted by the appellant composer. SIL argued that as the assignee of the original producer, it held the exclusive rights to the sound recording and the literary/musical works therein.

The appellant contended that as the composer, he remained the first owner of the musical work and held the right to make 'adaptations' under Section 14(a)(vi) of the Copyright Act, 1957, a right further protected by the 2012 amendments. The respondent countered that the song was commissioned for a film, making the producer the first owner under the first proviso to Section 17.

While the Court acknowledged the composer's separate copyright in the music, it ultimately held that since the new recording used both the original lyrics and a recreation of the sound recording belonging to the respondent, the appellant's license to the third party was invalid. The Court distinguished the ruling in RDB and Co. (HUF) v. Harpercollins Publishers India Pvt. Ltd. and referred to the principles in Indian Performing Right Society Ltd v. Eastern Indian Motion Pictures Assn to conclude that the injunction was justified.

Case Details:
Case No.: FAO(OS) (COMM) 52/2025
Case Title: MR ILAIYARAAJA v. SAREGAMA INDIA LIMITED
Appearances:
For the Petitioner(s): Ms. Swathi Sukumar, Sr. Adv. with Mr. Naveen Nagarjuna, Mr. Ritik Raghuwanshi, Ms. Rishika Agarwal and Ms. Shrudula Murthy, Advs.
For the Respondent(s): Mr. J. Sai Deepak, Sr Adv. with Mr. Ankur Sangal, Mr. Ankit Arvind, Mr. Shashwat Rakshit, Mr. Rishabh Rao, Advs.

Source: 2026 CaseBase(DEL) 354