The Madras High Court held that theatrical rights in a dubbed film do not automatically include satellite broadcasting rights. The Court dismissed Lahari Recording’s copyright claims over the Telugu dubbed version of Roja, ruling that the producer can assign different rights separately.
The Madras High Court has clarified that the assignment of theatrical rights in a dubbed film does not automatically include satellite broadcasting rights. While deciding two appeals filed by Lahari Recording Co. Pvt. Ltd., the Court ruled that satellite television rights and theatrical exhibition rights are separate components of copyright and can be granted independently by the producer of a film.
The Division Bench comprising Justice C.V. Karthikeyan and Justice K. Kumaresh Babu dismissed the appeals filed by Lahari Recording Company regarding the alleged unauthorized satellite telecast of the Telugu dubbed version of the Tamil film Roja.
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The Court upheld an earlier decision of a Single Judge and held that the company had only obtained limited rights to dub the film and exhibit it theatrically in certain regions. Since satellite rights were never granted to the company, it could not prevent the telecast of the film on satellite television.
The dispute arose from a 1992 agreement between Lahari Recording Co. Pvt. Ltd. and Kavithalayaa Productions Pvt. Ltd., the producer of the Tamil film Roja, directed by Mani Ratnam. Under the agreement dated June 16, 1992, Lahari paid ₹34.5 lakh to obtain exclusive rights to dub or remake the film into Telugu and commercially exploit the dubbed version in specific territories, including Andhra Pradesh and parts of Orissa, for a period of 25 years.
After acquiring the rights, Lahari dubbed the film into Telugu and released it in certain regions. However, in December 1994, the company came to know that Jain Television planned to telecast the Telugu version of the film through its satellite network. Believing that it held exclusive rights over the Telugu version, Lahari approached the court seeking a permanent injunction to stop the telecast.
In addition to the injunction, the company also filed another suit seeking damages of ₹1 crore, claiming that the satellite broadcast violated its copyright in the Telugu dubbed version of the film.
The defendants opposed the claim and argued that Lahari had only obtained rights related to dubbing and theatrical exhibition of the film in specified territories. According to them, satellite broadcasting rights were never transferred to Lahari and remained with the original producer. As the copyright owner, the producer had the legal authority to assign different rights in the film to different parties.
While examining the case, the High Court referred to Section 17 of the Copyright Act, 1957, which deals with ownership of copyright in cinematograph films. The Bench explained that the producer of a film is considered the first owner of the copyright and has the freedom to assign the copyright either completely or partially.
The judges explained the legal position in detail and stated,
“Under Section 17 of the Copyright Act, 1957, the person at whose instance for valuable consideration the cinemascope film is made is deemed to be the first owner of the copyright. In common parlance, such individual is called the producer of the film. It is at the instance of the producer for valuable consideration that any movie is made. As the first owner of the copyright, the producer has a right to assign the copyright either wholly or in parts. 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 producer can also assign the right to dub / remake of the movie in any other language and even for the dubbed versions, independently theatrical and satellite rights could be assigned to different individuals”.
The Court noted that the agreement relied upon by Lahari clearly restricted its rights only to dubbing the film into Telugu and exploiting the dubbed version mainly through theatrical exhibition in certain territories. The contract did not mention or grant satellite broadcasting rights.
Because of this limitation in the agreement, the Court held that Lahari could not claim control over satellite telecasts of the film. The Bench further clarified that satellite broadcasting rights had been granted separately by the producer to another party, which was legally permissible under copyright law.
Explaining why the plaintiff could not restrain the satellite telecast, the Bench stated,
“In view of the fact that satellite rights had not been granted, the appellant can never seek any relief restraining exploitation of the satellite rights by the 1st respondent to whom such rights had been specifically given by the producer of the movie / 2nd respondent. The arguments of the learned counsel for the appellant that under Section 13(1)(b) of the Copyright Act, 1957 the word ‘original’ had been omitted with respect to cinematograph films, would not take the appellant anywhere. 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 these findings, the High Court concluded that there was no copyright infringement in the satellite telecast of the Telugu version of the film. Since Lahari did not possess satellite broadcasting rights, its claim for injunction and damages could not be sustained.
Accordingly, the Court dismissed the appeals, upheld the earlier judgment of the Single Judge, and rejected Lahari’s claims for both an injunction and ₹1 crore in damages, with costs.
Advocate N. Surya Senthil, Partner at M/s. Surana and Surana, appeared for the appellant. Senior Advocate P.R. Raman represented the respondents, along with advocates S. Vijayaraghavan, A. Umasankar, and Kumarapal R. Chopra.
Case Title:
Lahari Recording Co. P. Ltd. v. Jain Television & Ors. (Mala Publicity Service P Ltd)
2026:MHC:942.
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