The Delhi High Court has held Paramvah Studios, led by Kannada actor-director Rakshit Shetty, liable for unauthorised use of songs in Bachelor Party. Accordingly, the Court directed payment of ₹25 lakh to MRT Music. It also imposed ₹5 lakh as costs for contempt.
Justice Tejas Karia delivered the ruling in MRT Music v. Paramvah Studios. The Court rejected the defence that the use of the songs was minimal. Instead, it found clear copyright infringement and wilful disobedience of court orders.
Copyright Infringement Claim Over Songs in Bachelor Party
The Court examined how the songs appeared in the film. First, it noted that “Omme Ninnanu” played for about 31 seconds. Further, “Nyaya Ellide” appeared for about 7 seconds.
The Court then relied on Section 14(d)(i)(A) of the Copyright Act. It observed that even a single frame forms part of the owner’s exclusive rights. Therefore, the defendants needed prior permission to use any portion of the works.
As a result, the Court held that the usage was not trivial. It also rejected the claim that the use was too minimal to require a licence.
Delhi High Court Rejects Minimal-Use Defence in Copyright Infringement Dispute
The Court next analysed how the songs supported the film’s narrative. It found that the filmmakers selected the songs deliberately and used them to advance the story.
In particular, the judge noted that “Nyaya Ellide” means “Where is the justice?”. The film played this song when the protagonist suffered. Thus, the Court viewed the choice as a deliberate attempt to highlight the character’s situation.
For that reason, the Court held that the use was not incidental. Rather, it was a conscious creative decision that supported the storyline.
Since the use served both a narrative and commercial purpose, the Court refused to accept the de minimis defence.
Assignment Rights and Section 19(4) Argument
MRT Music claimed ownership through a 2020 assignment deed. However, the defendants argued that the rights had lapsed under Section 19(4).
The Court rejected that argument. It found that MRT Music had continued to exploit the works, including on digital platforms. Moreover, the defendants produced no evidence of non-use.
Accordingly, the Court held that the rights remained valid on the date of the suit.
Contempt Finding Over Delay in Compliance
Earlier, on August 12, 2024, the Court had directed the defendants to deposit ₹20 lakh. In addition, it had ordered them to remove the infringing content.
However, the defendants did not comply within four weeks. Instead, they continued to exploit the songs. Consequently, MRT Music initiated contempt proceedings.
The defendants later deposited the amount during the proceedings. Nevertheless, the delay itself formed the basis of the contempt action.
The Court also considered an affidavit dated October 31, 2025. In that affidavit, the defendants expressed regret for their conduct. Even so, the Court found that contempt had been committed.
At the same time, the Court chose not to impose imprisonment. Instead, it directed the defendants to pay ₹5 lakh as exemplary costs to purge the contempt.
Financial Directions Issued by the Court
The Court, therefore, issued two financial directions:
- Release the ₹20 lakh already deposited by the defendants to MRT Music
- Pay an additional ₹5 lakh as costs for delayed compliance
Appearances
Senior Advocate Swathi Sukumar appeared for MRT Music. She was assisted by Advocates Asavari Jain, Geetanjali Visvanathan, Shivansh Tiwari, Ritik Raghuvanshi, Shrudula Murthy, Rishika Aggarwal, and Prathibha from Ira Law.
On the other side, Senior Advocate J Sai Deepak appeared for Paramvah Studios and the other defendants. He was assisted by Advocates Meenakshi Ogra, Samrat S. Kang, and Vishnu Gambhir.
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