Madras High Court dismisses Lahari Recording’s appeals, ruling it had no satellite rights over Roja’s Telugu version. Court clarifies that dubbing and theatrical rights do not include satellite broadcasting rights under copyright law.
The Madras High Court has dismissed two appeals filed by Lahari Recording in a long-standing copyright dispute related to the Telugu dubbed version of Mani Ratnam’s iconic 1992 film Roja. The Court made it clear that Lahari only had limited rights under its agreement and could not stop the telecast of the film on satellite television.
The case revolved around whether Lahari Recording had the authority to prevent Jain Television and others from broadcasting the Telugu dubbed version of Roja. After carefully examining the agreement and facts, the Court ruled against Lahari.
A Division Bench of Justices CV Karthikeyan and K Kumaresh Babu held that Lahari did not have satellite rights over the film and therefore could not claim any legal protection against its telecast. The Court clearly stated,
“The appellant can never seek injunction against the respondent for exploiting Telugu dubbed version of the Tamil movie Roja via., satellite as the appellant was granted only the right to dub the movie into Telugu and exploit the same in theatres and in television in specific areas stipulated under the agreement.”
The dispute goes back to an agreement dated June 16, 1992, between Lahari Recording and Kavithalayaa Productions, the original producer of Roja. As per Lahari, it had paid ₹34.5 lakh to acquire exclusive rights to dub or remake the film in Telugu and to exploit it for 25 years in certain regions like Andhra Pradesh, Rayalaseema, Nizam, Coastal Andhra, and Orissa.
Lahari argued that it invested significant money in dubbing the film into Telugu and even obtained certification in its own name. This included a certificate from the Central Board of Film Certification (CBFC) and a clearance certificate from the Film Publicity Clearance Committee, both issued on November 20, 1992. Based on this, Lahari claimed it had become the effective copyright holder and producer of the Telugu version.
However, the issue arose when Jain Television announced in December 1994 that it would broadcast the Telugu version of Roja on its satellite network. Lahari objected to this, claiming that it had not transferred any such rights and that the telecast would amount to copyright infringement.
The High Court, however, disagreed with Lahari’s claims. It explained that different types of rights in a film—such as theatrical rights and satellite broadcasting rights—are separate and can be independently assigned by the original copyright owner under Section 17 of the Copyright Act, 1957.
The Bench observed,
“At the time when the Tamil film Roja had been released, there were two separate and distinct rights which could be assigned by the first owner of the copyright namely, exhibition of the movie in theatres and exhibition of the movie via satellite television.”
The Court also pointed out that Lahari itself had gone beyond its permitted rights. It had entered into another agreement on January 25, 1993, granting video cassette rights to a third party, which was not allowed under its original agreement.
Highlighting this, the Court said,
“It is also to be noted that the appellant had violated their terms of the agreement by granting a right to the 3rd respondent to make video cassettes.”
On the issue of damages, the Court firmly held that Lahari had no valid claim since it never had satellite rights in the first place. Without such rights, there was no legal basis to claim infringement or seek compensation.
The Bench stated,
“The appellant’s rights are restricted only to the right granted by the first owner of the copyright, namely the 2nd respondent. The appellant cannot seek to expand that right any further.”
Based on all these findings, the Madras High Court concluded that Lahari Recording was not entitled to any injunction or damages related to the telecast of the Telugu dubbed version of Roja. The appeals were therefore dismissed.
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In terms of legal representation, Lahari Recording was represented by Advocate N Surya Senthil, instructed by Surana and Surana. Jain Television was represented by Advocate S Vijayaraghavan. Kavithalayaa Productions was represented by Senior Advocate PR Raman along with Advocate Umasankar. K Muni Kannaiah was represented by Advocate Kumarapal R Chopra.
This judgment is important because it clearly explains that copyright rights are limited to what is specifically granted in an agreement. It also reinforces that different rights—like theatrical release and satellite broadcasting—are separate and cannot be assumed unless clearly assigned.
Case Title:
Lahari Recording Co. P. Ltd. v. Jain Television & Ors. (Mala Publicity Service P Ltd)
2026:MHC:942.
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