Delhi High Court Sends ‘Oye Oye’ Song Copyright Dispute in Dhurandhar 2 to Mediation, Keeps OTT Exploitation Issue Open

Delhi High Court Sends ‘Oye Oye’ Song Copyright Dispute in Dhurandhar 2 to Mediation, Keeps OTT Exploitation Issue Open

Introduction

The Delhi High Court, through Justice Tushar Rao Gedela, referred the copyright dispute concerning the alleged unauthorised use of the iconic song Oye Oye (repurposed as “Rang De Lal”) in the movie Dhurandhar: The Revenge to mediation. The Court directed the parties Trimurti Films Pvt. Ltd., B62 Studios, and T-Series to appear before the Delhi High Court Mediation and Conciliation Centre, while declining to grant any interim injunction at this stage. The dispute now primarily concerns digital and OTT exploitation of the allegedly infringing track.

Factual Background

Trimurti Films Pvt. Ltd., claiming to be the copyright owner of the 1989 film Tridev, instituted the suit alleging that its iconic song Oye Oye, originally appearing in Tridev, had been lifted, repurposed, and commercially exploited in Dhurandhar: The Revenge under the altered title “Rang De Lal.”

According to the plaintiff, the defendants had not merely used the composition within the film but had independently monetised it as a standalone digital track across streaming and music platforms. It was contended that the altered title itself was intended to obscure the connection with the original song, especially since the phrase “Rang De Lal” allegedly does not appear in the original lyrics.

The plaintiff also relied on the fact that the end credits of the impugned film acknowledged the original lyricist Anand Bakshi and composers Kalyanji Anandji, which according to it reflected clear borrowing from the original copyrighted work.

Procedural Background

Trimurti Films approached the Delhi High Court seeking injunctive relief against the continued use and digital exploitation of the disputed song. Since the film had already been theatrically released, the immediate controversy shifted to its release and monetisation on OTT and digital music platforms.

At the first hearing, the defendants opposed interim relief and raised a serious objection of suppression, relying on an earlier 2016 legal notice exchanged in relation to use of the same song in the film Azhar, which according to them had not been disclosed by the plaintiff.

Issues

1. Whether the use of Oye Oye as “Rang De Lal” in Dhurandhar: The Revenge amounted to copyright infringement.

2. Whether the plaintiff was guilty of suppression by failing to disclose the 2016 notice exchange relating to the same song.

3. Whether interim injunctive relief should be granted pending adjudication.

Contentions of Parties

The plaintiff contended that the 1988 agreement executed with T-Series was only a limited assignment confined to exploitation within the original film Tridev and did not authorise fresh repurposing in a new film or separate digital monetisation. It was argued that the defendants had unlawfully appropriated both the musical composition and sound recording and were commercially exploiting the work beyond the scope of any original licence.

T-Series, opposing interim relief, alleged gross suppression and perjury by the plaintiff. It relied on the plaintiff’s 2016 legal notice concerning use of the same song in Azhar and the defendants’ reply asserting their rights, contending that the omission of these documents disentitled the plaintiff from any equitable relief.

B62 Studios submitted that although the film was presently in theatres, it was unlikely to release on OTT platforms until mid-May, thereby reducing the urgency for immediate interim restraint.

Reasoning and Analysis

The bench of Justice Tushar Rao Gedela took note of the serious allegation of suppression raised by the defendants and observed that if the 2016 documents indeed existed in the manner asserted, it would constitute a significant issue requiring closer judicial scrutiny. Justice Gedela specifically remarked that such non-disclosure, if established, would be a serious matter affecting the plaintiff’s claim for equitable interim relief.

At the same time, the Court also recognised that the dispute involved continuing commercial exploitation of a valuable copyrighted song in the digital domain and that an immediate adversarial determination might not be the most efficient course at this stage.

Considering the nature of the dispute, the existing theatrical release, and the possibility of settlement on digital exploitation terms, the Court found mediation to be an appropriate interim course. It therefore referred the parties to the Delhi High Court Mediation and Conciliation Centre without prejudice to their respective rights and contentions.

Decision

The Delhi High Court referred the copyright dispute to mediation and directed the parties to appear before the Mediation and Conciliation Centre on 22 April 2026. No interim injunction was granted at this stage, and the issue of digital exploitation remains open pending mediation and further judicial consideration.

In this case B62 Studios was represented by Senior Counsel Ravi Prakash, Parag Khandhar (Partner DSK legal ) with Advocates Chandrima Mitra, Anaheeta Verma, Krishan Kumar, and Diva Chanchani. Meanwhile T-Series was represented by Senior Counsel Akhil Sibal briefed by Ira Law with Advocates Aditya Gupta, Asavari Jain, Geetanjali Visvanathan and Shivansh Tiwari.