Bombay High Court Upholds Producer's Exclusive Copyright Over Musical Works

Defendant's Unauthorized Online Release Halted; Court Grants Interim Injunction Protecting Intellectual Property Rights

In a significant ruling on December 5, 2025, the Bombay High Court, presided over by Justice Sharmila U. Deshmukh, delivered a judgment affirming the exclusive ownership of copyright to Rao and Sapru Films Pvt. Ltd. over a series of musical works. The court granted an interim injunction restraining the defendant, Alok Kumar, from exploiting the musical works, which he had allegedly released online without authorization.

The legal dispute centered around musical compositions created under a Music Director Agreement, Lyric Writer Agreement, and Singer Agreement, all dated December 16, 2023, between the plaintiff, Rao and Sapru Films Pvt. Ltd., and the defendant, Alok Kumar. The plaintiff argued that as the producer, they held exclusive copyright ownership over the works, which were created under a contract of service and through assignment agreements.

The court found that the agreements clearly established the plaintiff's ownership of the copyright, dismissing the defendant's claim of ownership and his unauthorized release of the works online. The court ruled that the agreements were binding and that no substantive evidence of fraud or misrepresentation was presented by the defendant, despite claims of having signed the contracts under duress and without full understanding.

The judgment emphasized the contractual terms, which specifically excluded the applicability of Section 19(4) of the Copyright Act, 1957, preventing any lapse of assignment rights due to delayed release. The court underscored that statutory provisions must yield to contractual terms, affirming the plaintiff's ongoing rights to the musical works.

Justice Deshmukh ordered the defendant to remove the works from all platforms and deliver related materials to the plaintiff, recognizing the plaintiff's prima facie case for ownership and the potential for irreparable damage from unauthorized use.

This ruling highlights the importance of clear contractual agreements in the entertainment industry, particularly regarding intellectual property rights, and reinforces the judiciary's role in upholding such agreements to protect creative works from unauthorized exploitation.

Bottom Line:

Copyright Law - Exclusive ownership of copyright and intellectual property rights in musical works created under a contract of service and assignment agreements - Interim relief granted to restrain unauthorized exploitation of such works.

Statutory provision(s): Copyright Act, 1957 Sections 2(d), 2(ffa), 14, 17, 18, 19, 19A

Rao and Sapru Films Pvt. Ltd. v. Alok Kumar, (Bombay) : Law Finder Doc Id # 2819195