Madras High Court Reserves Order In Ilaiyaraaja–Mythri Movie Makers Copyright Row Over Songs In Ajith’s ‘Good Bad Ugly’
Madras High Court Reserves Order In Ilaiyaraaja–Mythri Movie Makers Copyright Row Over Songs In Ajith’s ‘Good Bad Ugly’
Introduction
The Madras High Court has reserved its order on an application filed by Mythri Movie Makers, producers of the Ajith Kumar starrer “Good Bad Ugly”, seeking to vacate an interim injunction obtained by veteran composer Ilaiyaraaja in a copyright dispute concerning three of his iconic songs. The case, which brings to the forefront questions of ownership, licensing, and moral rights of composers, was heard by Justice N. Senthilkumar, who reserved judgment on November 6, 2025, after hearing detailed arguments from both sides.
Factual Background
The dispute arises from the alleged use of three classic Ilaiyaraaja compositions — “Otha Rubayum Tharen” (from Nattupura Pattu), “Ilamai Idho Ido” (from Sakalakala Vallavan), and “En Jodi Manja Kuruvi” (from Vikram) — in the film Good Bad Ugly produced by Mythri Movie Makers. Ilaiyaraaja filed a copyright suit alleging that these songs had been used without his express consent or authorization, and without payment of statutory royalties. He claimed that the use amounted to infringement of his copyright and violation of his moral rights as the creator. In September 2025, the Court issued a temporary injunction restraining Mythri Movie Makers from using the songs in any form pending adjudication of the dispute.
Procedural Background
Following the interim injunction, Mythri Movie Makers moved an application seeking to set aside the restraint order, arguing that they had acquired rights to the songs through valid agreements with music labels who were the purported rights holders. During the hearing, Senior Advocate P.V. Balasubramaniam and Advocate Navod Prasannan appeared for Mythri Movie Makers, while Advocate A. Saravanan represented Ilaiyaraaja. The Court also heard counsel representing the concerned music labels who were impleaded as parties, given the conflicting claims of ownership. After hearing all sides, Justice Senthilkumar reserved orders on the application on November 6, 2025.
Issues
- Whether Mythri Movie Makers’ use of the songs amounted to copyright infringement in absence of express permission from Ilaiyaraaja.
- Whether Ilaiyaraaja had assigned or retained ownership and moral rights over the songs composed for the earlier films.
- Whether the music producers of the original films, or the music labels, held the copyright in the songs.
- Whether the interim injunction restraining use of the songs was justified given the timing of Ilaiyaraaja’s application.
Contentions of the Parties
For Mythri Movie Makers: Senior Advocate Balasubramaniam argued that the production company was caught in a crossfire between Ilaiyaraaja and the music labels, both claiming ownership. He contended that since the films were produced before the 1994 Copyright Amendment, the producers of the original films were the lawful owners of the songs, not the composer. He also highlighted that Ilaiyaraaja delayed filing for injunction, as the movie had already been released in April 2025 and streamed on OTT platforms by September. The delay, he said, indicated a lack of urgency and undermined the claim for interim relief. Balasubramaniam further submitted that Mythri had acted in good faith and would duly compensate the rightful owner once ownership was judicially determined.
For Ilaiyaraaja: Advocate A. Saravanan, representing Ilaiyaraaja, contended that the composer was not seeking monetary compensation but recognition of his authorship and creative ownership. He argued that the composer retains copyright and moral rights, and that using his works without consent amounted to unauthorized appropriation. He maintained that Ilaiyaraaja had never assigned full ownership to the producers or music labels and that earlier agreements merely granted limited licenses for cassette and record distribution. The rights, therefore, did not extend to synchronization in a new film or OTT exploitation. Saravanan emphasized that there was no employer-employee relationship between the composer and the producers, asserting that Ilaiyaraaja’s musical works stand independently of the cinematograph films.
Reasoning and Analysis
The Court heard detailed arguments over ownership of music created prior to the 1994 Copyright Amendment, which clarified composers’ rights in film music. While Mythri claimed that the producers of the old films were the original owners, Ilaiyaraaja asserted that his authorship and moral rights survived, especially since no document showed complete assignment of copyright.
The Judge noted the competing claims between Ilaiyaraaja and the music labels, each asserting ownership under separate legal grounds. The arguments also highlighted the legal tension between Section 17(b) and Section 57 of the Copyright Act, concerning employer ownership and the author’s moral rights. After considering submissions, Justice Senthilkumar reserved the order, indicating that the Court would carefully assess whether the injunction should continue, given the movie’s release and the complex question of ownership rights.
Implications
This case has far-reaching implications for intellectual property rights in Indian cinema, especially for works created before the 1994 Copyright (Amendment) Act. It raises critical questions about whether music composers retain control over their compositions in films made under older contracts and how far moral rights extend in modern adaptations and remakes. A ruling in Ilaiyaraaja’s favour could reaffirm composers’ residual rights over older works, impacting film remakes, digital releases, and streaming rights. Conversely, a decision for Mythri Movie Makers could consolidate producers’ ownership of pre-amendment works and set a precedent for reusing old songs in new films.
