'Ilaiyaraaja Had No Copyright Over En Iniya Pon Nilave ': Delhi HC Dismisses Appeal Against Single-Bench Order

The Delhi High Court has dismissed music composer Ilaiyaraaja's appeal against a single-judge order that had, at an interim stage, recognised Saregama India Limited's rights over the classic Tamil song En Iniya Pon Nilave from the 1980 film Moodu Pani.

A Division Bench of Justice C. Hari Shankar and Justice Om Prakash Shukla pronounced the judgment on Thursday.

"However, Ilaiyaraaja was not the owner of copyright in the sound recording, or the lyrics underlying the disputed song. His copyright was limited to the musical work, the very definition of which, in Section 2(p), excludes the lyrical component of the song. Ilaiyaraaja could not, therefore, have assigned, to VFIL, the lyrics underlying the disputed song," it observed.

The dispute began in January 2025, days before the release of Tamil film Aghathiyaa, produced by Vels Film International Limited.

Saregama said it discovered that the film featured a recreated version of the song and issued a cease-and-desist notice on January 10, 2025.

Vels Film responded the next day, saying it had obtained a licence from Ilaiyaraaja, who had composed the original song.

Saregama then moved the Delhi High Court, which on January 16 passed an interim order restraining the defendants from releasing the song on any platform.

On January 30, Justice Mini Pushkarna held, at a prima facie stage, that Saregama appeared to hold the relevant rights in the musical and literary works of the song through a 1980 assignment agreement executed between the film's producer, Raja Cine Arts, and Saregama, then known as The Gramophone Company of India Limited.

The court held that under the copyright law applicable at the time, the producer held the relevant rights in the film's soundtrack unless there was an agreement to the contrary. Since Raja Cine Arts had assigned those rights to Saregama, the court held that Ilaiyaraaja could not independently license the song to a third party.

Ilaiyaraaja had argued that his independent copyright in the musical composition survived even after the song became part of the film, and that amendments introduced to copyright law in 2012 strengthened those rights.

The single judge rejected those arguments, holding that the 2012 amendment could not apply retrospectively to an agreement executed in 1980.

The court also rejected the argument that the use in Aghathiyaa qualified as an adaptation, noting that the defendants had used the lyrics and musical composition to create a fresh recording.

It further held that since Ilaiyaraaja was the composer and not the lyricist of the original song, he had no rights over the lyrics and could not have licensed them to Vels Film.

The appeal was accordingly dismissed.

For Ilaiyaraaja: Senior Advocate Swathi Sukumar with Advocates Naveen Nagarjuna, Ritik Raghuwanshi, Rishika Agarwal and Shrudula Murthy

For Saregama: Senior Advocate J. Sai Deepak with Advocates Ankur Sangal, Ankit Arvind, Shashwat Rakshit and Rishabh Rao