Madras High Court Rejects Lahari Recording's Claim Over Satellite Telecast of Telugu-Dubbed 'Roja'

The Madras High Court has dismissed appeals filed by Lahari Recording Co. Pvt. Ltd. over the satellite telecast of the Telugu-dubbed version of Roja, the Mani Ratnam-directed Tamil film that became one of Indian cinema's most recognisable titles of the 1990s.

The company had sought to block the broadcast and claim Rs 1 crore in damages, arguing that the telecast infringed its rights in the dubbed version.

A division bench of Justice C.V. Karthikeyan and Justice K. Kumaresh Babu, in a judgment pronounced on March 6, 2026, found that Lahari Recording's rights flowed solely from a 1992 agreement with the film's producer. That agreement, the Court noted, permitted the company to exploit the Telugu-dubbed version in theaters within specified territories, but it did not grant satellite television rights.

Kavithalayaa Productions, which produced the original film, remained the first owner of the copyright. As such, the producer was free to assign different components of the copyright separately. The bench said Lahari Recording could rely only on the rights expressly granted to it and could not enlarge those rights to challenge the satellite telecast.

The bench held that Lahari Recording could not seek to expand the limited rights granted to it under the agreement.

The bench also clarified that the producer of a cinematograph film remains the first owner of the copyright and has the authority to assign that copyright wholly or in parts to different entities.

Lahari Recording had approached the court seeking a permanent injunction to prevent the telecast of the Telugu dubbed version of Roja through satellite networks, alleging that such broadcasts infringed its exclusive rights.

The appeals were filed under Order XXXVI Rule 1 of the Original Side Rules read with Clause 15 of the Letters Patent, challenging the Single Judge's judgment dated January 5, 2016, which had dismissed two civil suits filed by the company.

The Single Bench had dismissed the suits with costs, holding that Lahari Recording had not been specifically assigned satellite rights and therefore could not claim that the telecast infringed its copyright.

Lahari Recording contended that its 1992 agreement to dub Roja into Telugu, combined with the substantial costs incurred for dubbing and the Censor Certificate issued in its name, made it the “first owner” of the copyright in the Telugu version. On this basis, the company alleged that Jain Television's 1994 announcement that it would telecast the Telugu version of the film through its satellite network constituted unlawful infringement of its exclusive rights.

However, Kavithalayaa Productions argued that the agreement granted Lahari only the right to dub the film and exploit the Telugu version in theaters within specified territories for a limited period and did not extend to satellite television rights. The respondents also contended that satellite rights in the film had been separately assigned, and therefore Lahari had no authority to prevent the telecast.

The Court observed that under Section 17 of the Copyright Act, the producer of a cinematograph film is the first owner of the copyright and is entitled to assign that copyright either wholly or in parts.

The bench noted that at the time of the film's release there were “two separate and distinct rights, which could be assigned by the first owner of the copyrightnamely, exhibition of the movie in theatres and exhibition of the movie via satellite television.”

The court further held that while a producer may grant the right to dub a film into another language, the theatrical and satellite rights of that dubbed version can be assigned independently to different parties.

Examining the agreement between the parties, the High Court found that satellite rights had not been specifically assigned to Lahari Recording. The court remarked that the company's rights were strictly “restricted only to the right granted by the first owner of the copyright” and that it “cannot seek to expand that right any further.”

Consequently, the court held that the telecast of the Telugu dubbed version of Roja through satellite television did not infringe any right held by the company. Affirming the earlier dismissal of the suits, the High Court ruled that Lahari Recording was not entitled to an injunction or the claimed damages and dismissed the appeals with costs.