Delhi High Court Confirms Order Directing Kannada Film Mask Makers To Remove 'Naguva Nayana' Or Deposit ₹30 Lakh

The Delhi High Court on Wednesday made absolute an earlier ex parte ad-interim injunction in a copyright suit filed by Saregama India Ltd. against Black Madras Films. The suit concerns the unauthorised use of the classic Kannada song Naguva Nayana in the Kannada film Mask.

By doing so, a single-judge bench of Justice Tushar Rao Gedela confirmed its earlier direction requiring the makers of Mask to either remove the song from the film before its OTT release or deposit ₹30 lakh with the court as interim licence fees.

Naguva Nayana is from the 1983 Kannada film Pallavi Anu Pallavi, directed by Mani Ratnam with music composed by Ilaiyaraja. The film was produced by Venus Pictures, which assigned the copyright in the sound recordings and the underlying literary and musical works to Saregama under a copyright assignment agreement dated December 27, 1980.

Mask was released in theaters on November 21, 2025. Saregama claimed it learned five days later that the song had been used as the film's background score without its licence. After issuing a cease-and-desist notice, it approached the High Court when the filmmakers claimed they had obtained a licence directly from Ilaiyaraja.

Saregama argued that although Ilaiyaraja composed the song, he had no authority to license it. Relying on Section 17(b) of the Copyright Act, it contended that the producer of a cinematographic film is the first owner of the copyright in music created for the film, unless there is an agreement to the contrary, and that those rights had been assigned to Saregama.

The High Court accepted Saregama's prima facie case, holding that the music label was the prima facie owner of the copyright and that Ilaiyaraja had no right to license the song for use in Mask. It also noted that it had reached the same conclusion in a similar copyright dispute between Saregama and VELS Film International in January 2025.