Madras High Court Revives Sreedevi Video's Dispute With Saregama Over Rights To Tamil, Telegu Film Music

The Madras High Court has revived a copyright dispute over the audio rights to iconic Telegu and Tamil films including Sagara Sangamam, Salangai Oli, Shankarabharanam and Sitara, holding that Sreedevi Video Corporation's claim seeking a permanent injunction against Saregama India Ltd must be examined on merits even though its request for a declaration of ownership is time-barred. On November 19, 2025, a Division Bench of Justice G Jayachandran and Justice Mummineni Sudheer Kumar partly set aside a 2022 decision of a Single Judge who had dismissed the entire suit as barred by limitation. The bench held that the court below had erred in treating the injunction prayer as merely consequential to the declaration relief. While agreeing that the claim for declaration was filed more than three years after Saregama's letter dated August 6, 2010, and was therefore beyond the three-year limitation period under Article 58 of the Limitation Act, the Court held that the injunction claim required independent consideration.The court stated that limitation affects the remedy but does not destroy the underlying right. It said,“Mere fact that the relief of declaration is declined on the ground of limitation, the same will not have the effect of conferring title on the 1st defendant. It is only in case the relief of declaration sought by the plaintiff is declined by the Court on examining the rival case set up by the plaintiff and defendant on merits, and in the event of arriving at a conclusion that the plaintiff has failed to establish its right and title while the 1st defendant is able establish his right and title, the relief of permanent injunction sought by the plaintiff cannot be granted.” The court noted that Sreedevi had sought injunction as an independent relief, paid separate court fees, and that an action for injunction under Section 55 of the Copyright Act can arise from a distinct cause of action. The court also held that suits seeking injunction are generally governed by Article 113 of the Limitation Act, which provides a three-year limitation period starting from the date the right to sue actually arises (that is, the last date on which the cause of action occurs), and not by Article 58, which prescribes a three-year period from when the right to sue first arises. Article 58 applies only when the injunction sought is purely consequential. The order observed that the Single Judge had provided no reasoning to conclude that the injunction relief depended on the declaration, describing that approach as legally unsustainable. Sreedevi Video Corporation contended that it acquired audio rights in July 2008 through assignment deeds from Poornodaya companies and that it had been exploiting the tracks since then. Saregama asserted ownership in 2010 and called on Sreedevi to cease exploitation. The suit was filed in May 2014 seeking declaration and permanent injunction. The Single Judge dismissed the suit without entering into the merits of the dispute. Setting aside the Single Judge's order that the suit was wholly barred, the Division Bench remanded the matter back to him to decide the claim for permanent injunction after a full trial, clarifying that it was expressing no view on whether the injunction plea is within limitation. The bench requested that the matter be disposed of expeditiously, noting that the suit was filed in 2014 Case Title: Sreedevi Video Corporation v. SaReGaMa India Ltd.Citation: 2025 LiveLaw (Mad) 434 Case Number: OSA (CAD) No.20/2022 For Appellant: Advocate K Harishankar For Respondent: Senior Advocate PR Raman for Advocate Abishek Jenasenan Click Here To Read/Download The Order

Madras High Court Revives Sreedevi Video's Dispute With Saregama Over Rights To Tamil, Telegu Film Music

Ayushi Shukla

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