Summary
In M/s. Sreedevi Video Corporation vs M/s. Saregama India Ltd., the Madras High Court ruled that in a copyright dispute over film soundtracks including Salangai Oli, Sagara Sangamam, and Shankarabharanam, the right to seek an injunction under Section 55 of the Copyright Act based on infringement claims survives independently, even when a related claim for declaration is barred by limitation. The dispute arose from competing assignments of audio rights from the same producers to two different parties.
Competing Copyright Assignments in Film Soundtracks
This case concerns copyright in the soundtracks of several iconic South Indian films, including Salangai Oli, Sagara Sangamam, and Shankarabharanam. The appellant, Sreedevi Video Corporation, claimed rights in the audio tracks based on two assignment deeds executed in July 2008 by the original producers, Poornodaya Movie Creations and Poornodaya Art Creations.
In 2010, the first respondent, Saregama India Ltd., claimed ownership over the same works through a prior assignment in favour of its predecessor, Sea Records. Following a cease-and-desist notice issued by Saregama, Sreedevi filed a suit in 2014 for declaration of ownership and a permanent injunction.
Questions Before the Court
- Whether the suit for declaration was barred by limitation under Article 58 of the Limitation Act?
- Whether a permanent injunction could be maintained as an independent claim under the Copyright Act?
- Whether the plaintiff’s assignment deeds conveyed enforceable rights?
Arguments and Court’s Reasoning
The trial court dismissed the entire suit, holding that the declaratory relief was time-barred and that the injunction claim was merely consequential.
On appeal, the High Court disagreed. It held that the permanent injunction was pleaded as an independent remedy supported by a separate cause of action. The court stated that under Section 55 of the Copyright Act, any copyright owner may seek an injunction against infringement without seeking a declaration of ownership.
The court acknowledged that both parties traced their title to the same producers and that the conflicting assignments created disputed facts requiring trial. It remanded the case for a full hearing on the injunction claim.
Findings
- The court affirmed that the declaratory relief was barred by limitation.
- It reversed the trial court’s conclusion that the entire suit was not maintainable.
- It allowed the claim for permanent injunction to proceed.
Relevant Paragraphs
Para 14: “The learned Single Judge came to the conclusion that the relief of permanent injunction is dependent upon the relief of declaration… There is no other discussion or reasoning on this aspect in the entire judgment.”
Para 22: “The relief of permanent injunction sought for by the plaintiff as an independent relief… can be construed as a relief under Section 55 of the Copyright Act, 1957…”
Para 27: “We are not inclined to interfere with the findings… in so far as declaring the relief of declaration as barred… while setting aside the finding that the suit in its entirety is barred…”
Case Citation
M/s. Sreedevi Video Corporation vs M/s. Saregama India Ltd., OSA (CAD) No. 20 of 2022, Madras High Court, decided on 19 November 2025
Indian Kanoon Link: http://indiankanoon.org/doc/197172165/ (Accessed on 20 December 2025)
Disclaimer
This blog post reflects the author’s understanding of the court judgment. Interpretations may vary. Portions of this note were generated using AI tools. Views expressed are personal.
