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.<\/p>\n
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.<\/p>\n
The trial court dismissed the entire suit, holding that the declaratory relief was time-barred and that the injunction claim was merely consequential.<\/p>\n
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.<\/p>\n
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.<\/p>\n
Para 14: \u201cThe learned Single Judge came to the conclusion that the relief of permanent injunction is dependent upon the relief of declaration\u2026 There is no other discussion or reasoning on this aspect in the entire judgment.\u201d<\/p>\n
Para 22: \u201cThe relief of permanent injunction sought for by the plaintiff as an independent relief\u2026 can be construed as a relief under Section 55 of the Copyright Act, 1957\u2026\u201d<\/p>\n
Para 27: \u201cWe are not inclined to interfere with the findings\u2026 in so far as declaring the relief of declaration as barred\u2026 while setting aside the finding that the suit in its entirety is barred\u2026\u201d<\/p><\/blockquote>\n
Case Citation<\/h5>\n
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<\/p>\n