Court Rules Plaintiff M/s MRT Music Holds Exclusive Copyright; Defendants’ Fair Use and Forum Shopping Claims Rejected; Orders Rs. 5 Lakh Cost for Contempt
In a significant copyright infringement ruling dated March 28, 2026, the Delhi High Court, presided over by Justice Tejas Karia, delivered a judgment in favor of M/s MRT Music, affirming its exclusive ownership of copyright over two original songs, “Nyaya Ellide” and “Omme Ninnanu,” used without authorization in the film “Bachelor Party,” produced by Paramvah Studios Private Limited and others.
M/s MRT Music, a partnership firm engaged in acquisition and production of sound recordings and cinematograph films, asserted ownership of the copyrighted works by virtue of assignment deeds from the original rights-holder, Sangeetha. The defendants incorporated these songs into their film without obtaining a license, despite initially approaching M/s MRT Music for permission, which was denied due to non-payment of the quoted license fee.
The court examined several key legal issues, including ownership of copyright, the applicability of fair use and de minimis exceptions, licensing authority under Section 33 of the Copyright Act, territorial and pecuniary jurisdiction, and the defendants' alleged contempt of court.
On ownership, the court relied on the Assignment Deed and related agreements, concluding prima facie that M/s MRT Music held exclusive rights to the audio-visual recordings, sound recordings, and underlying literary and musical works embodied in the songs. The defendants failed to prove any contrary claim and had not taken any license from other parties, thus infringing the plaintiff’s rights.
The defendants argued their use was incidental and fell under fair use or de minimis exceptions, highlighting the short duration (7 and 31 seconds) of the songs’ appearance. The court rejected these defenses, emphasizing the qualitative significance of the songs to the film’s plot and noting the defendants had licensed other songs for similar durations, underscoring the requirement for licensing regardless of length. The court held that even a single frame of an audio-visual work is protected under copyright law.
Regarding licensing authority, the defendants contended M/s MRT Music could not license works without being a registered copyright society under Section 33 of the Copyright Act. However, the court clarified that Section 33 regulates copyright societies but does not restrict individual owners or assignees from granting licenses for their own works. The plaintiff was thus entitled to issue licenses in its individual capacity.
The court also addressed territorial jurisdiction, finding the suit maintainable in Delhi since the impugned film was accessible on OTT platforms within the court’s jurisdiction, and a subordinate office of the plaintiff was located in Delhi. The defendants’ claim of forum shopping was dismissed. Similarly, pecuniary jurisdiction was upheld based on the license fee quoted and damages claimed, exceeding the threshold under the Commercial Courts Act.
Further, the court found that the defendants had willfully disobeyed an interim injunction order dated August 12, 2024, which directed them to deposit Rs. 20,00,000 as license fee. Despite belated deposit, the court imposed exemplary costs of Rs. 5,00,000 on the defendants to purge contempt, rejecting their excuse that pending modification applications excused non-compliance.
Balancing equities, the court ordered the Rs. 20,00,000 deposited by the defendants to be released to M/s MRT Music pending final adjudication, and restrained the defendants from further unauthorized use of the copyrighted works in the film.
This ruling underscores the importance of respecting copyright ownership and the necessity of obtaining valid licenses for use of copyrighted audio-visual content, reinforcing protections under the Copyright Act, 1957. It also clarifies that individual copyright owners are entitled to grant licenses without registration as copyright societies.
Bottom Line:
Ownership of copyright in audio-visual recordings, sound recordings and underlying literary and musical works - Plaintiff shown to be exclusive owner by assignment deed - Defendants used Original Works without license - Held, prima facie case of infringement made out - Defendants liable to be restrained from such use.
Statutory provision(s):
Copyright Act, 1957 Sections 13, 14, 16, 18, 19, 33, 34, 51, 55, 62; Code of Civil Procedure, 1908 Order XXXIX Rules 1, 2, 2A, 4; Commercial Courts Act, 2015; Contempt of Courts Act, 1971 Section 12
M/s MRT Music v. Paramvah Studios Private Limited, (Delhi) : Law Finder Doc id # 2875316
