The Delhi High Court has ruled that music composer Ilaiyaraaja holds no copyright over the lyrics or sound recording of the Tamil song ‘En Iniya Pon Nilave’. A Division Bench of Justice C Hari Shankar and Justice Om Prakash Shukla delivered the judgment on May 21, 2026. The bench upheld an earlier January 2025 order passed by a Single Judge. The verdict was a decisive win for Saregama India Limited.
‘En Iniya Pon Nilave’ is a well-known Tamil song from the 1980 film ‘Moodu Pani’. The film was produced by Raja Cine Arts. Ilaiyaraaja composed the music for the song. He was not, however, its lyricist. This distinction became a key point in the court’s reasoning.
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How the dispute began
The case was triggered by the upcoming Tamil film ‘Aghathiyaa’, produced by Vels Films International (VFIL). The teaser of ‘Aghathiyaa’ showed use of a recreated version of ‘En Iniya Pon Nilave’ using its original lyrics and composition. Saregama sent cease-and-desist notices to VFIL in January 2025.
When those were ignored, Saregama filed a copyright infringement suit in the Delhi High Court.
The court initially allowed VFIL to use the recreated song in the film, provided they deposited ₹30 lakh as a licence fee. ‘Aghathiyaa’ was scheduled to release on January 31, 2025. VFIL later chose to release the film without the song entirely.
Ilaiyaraaja’s claim and the appeal
Ilaiyaraaja challenged the Single Judge’s January 2025 order. He argued that as the original composer of the musical work, he retained the right to adapt and license the song. His legal team also argued that clauses (b) and (c) of the first proviso to Section 17 of the Copyright Act automatically took away his ownership.
The Division Bench rejected both arguments. The court found no pleading or material evidence showing a “contract of service” that would trigger those clauses.
What the court said
The court examined the difference between copyright in a cinematograph film and copyright in the underlying musical work. It confirmed that both can coexist. However, it drew a clear line between what a music composer owns and what belongs to the producer’s sound recording.
Under Section 2(p) of the Copyright Act, the term “musical work” covers only the musical component of a song. It does not include lyrics or sound recordings. Since Ilaiyaraaja was never the lyricist, he had no rights over the lyrics in the first place. He could not assign rights he did not own.
The court also referred to Section 2(f) of the Copyright Act, which defines a cinematograph film. The definition includes sound recordings that accompany the visual recording. On this basis, the court held that the copyright in the film ‘Moodu Pani’, including its soundtrack, vested with the producer, Raja Cine Arts.
The 2012 amendment argument rejected
Ilaiyaraaja’s legal team invoked the 2012 amendment to the Copyright Act. They argued it gave composers additional rights over their works.
The court rejected this. The 2012 amendment, it held, cannot be applied retrospectively. The song and the original rights agreement predate the amendment by over three decades.