11 Dec 2025

Saregama India Limited v Black Madras Films and Ilaiyaraja — Delhi High Court Restrains OTT Release of MASK

"Khaitan & Co represented Saregama India Limited in a copyright suit against Black Madras Films and composer Ilaiyaraja over use of the song “Naguva Nayana” in the film MASK. The Delhi High Court held that Ilaiyaraja, as music composer, cannot grant a licence to the sound recording and restrained Black Madras Films from releasing MASK on OTT without Saregama’s licence."

Khaitan & Co represented Saregama India Limited in litigation against Black Madras Films and composer Ilaiyaraja before the Delhi High Court. The suit concerned alleged copyright infringement arising from the use of the song “Naguva Nayana” in the film MASK. During the hearing, the Delhi High Court clarified that Ilaiyaraja, in his capacity as the music composer, does not possess the right to grant a copyright licence in respect of the sound recording. On that basis the Court restrained Black Madras Films from releasing the film MASK on over‑the‑top (OTT) platforms unless and until a copyright licence is obtained from Saregama India Limited. Khaitan & Co represented Saregama India Limited with a team composed by: Ankur Sangal (Partner), Shashwat Rakshit (Senior Associate) and Amrit Sharma (Associate).
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