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The Supreme Court reportedly declined to entertain composer Ilaiyaraaja’s challenge to a Delhi High Court ruling over “En Iniya Pon Nilave,” from the Tamil film Moodu Pani. The High Court recognized his copyright in the music he composed, but held that this did not by itself authorize use of the song’s lyrics or its existing sound recording. The Supreme Court order itself was not available in the reporting reviewed, so its precise operative wording is not established.
What the Supreme Court reportedly decided
On 1 October 2026, Bar and Bench reported that a Supreme Court bench comprising Justices JB Pardiwala and K Vinod Chandran declined Ilaiyaraaja’s appeal. Hindustan Times also reported that the Court refused to interfere with the Delhi High Court ruling. Neither report supplies the Supreme Court order text, so it is safest to describe the result as a reported refusal to entertain or interfere—not as a quoted ruling or a detailed Supreme Court determination of copyright law. Bar and Bench’s report and Hindustan Times’ report describe the outcome.
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Why one song can involve several separate rights
The Delhi High Court’s 21 May 2026 division-bench judgment treated “song copyright” not as one indivisible right, but as distinct rights in the musical composition, the lyrics, and the sound recording. That distinction explains why a license from the composer alone did not clear the proposed use in this dispute.
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|---|---|---|
| Musical work | The music or composition, excluding lyrics | Ilaiyaraaja, as composer, was the author of this musical component and held copyright in it. |
| Lyrics | The words of the song | The court treated the lyrics as belonging to the lyricist, not as part of the composer’s musical-work copyright. |
| Sound recording | The fixed recording of the performance | The court held that the relevant recording rights vested with the film producer and were later assigned to Saregama. |
The division bench put the composition point this way: “As the composer of the disputed song, therefore, Ilaiyaraaja was the author of the ‘musical work’ forming part thereof, i.e., the musical component of the disputed song.” It added: “That right could not, however, extend to doing anything involving the sound recording of the disputed song, or the lyrics thereof.” These are statements from the Delhi High Court division bench in Mr Ilaiyaraaja v. Saregama India Limited, decided 21 May 2026. Read the division-bench judgment.
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The judgment discussed sections 2(d), 2(f), 2(p), 13(4), 14(a), and 17 of India’s Copyright Act, 1957. Its reasoning was that a musical work excludes lyrics, while the composer’s right to adapt that work did not extend to using the lyrics or the existing sound recording. This explains the judgment’s result on these facts; it should not be read as a universal rule for every film-song contract or composer.
How the dispute reached the Supreme Court
- Proposed use in a film: Vels Film International (VFIL) used a recreated version of “En Iniya Pon Nilave” in Aghathiyaa, saying it had obtained rights from Ilaiyaraaja.
- Saregama’s objection: Saregama asserted sound-recording rights through an assignment from the original producer. The High Court record traces the assignment from RCA to Saregama to an agreement dated 25 February 1980.
- Delhi High Court ruling: On 21 May 2026, a division bench upheld the single judge’s decision and injunction against the proposed use.
- Review dismissed: The High Court dismissed the review petition on 26 May 2026. Read the review judgment.
- Supreme Court challenge: On 1 October 2026, news reports said the Supreme Court declined to entertain Ilaiyaraaja’s challenge.
Hindustan Times’ account of the dispute and assignment is available here.
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What the ruling means for a recreated version
Recreating a song is not necessarily the same as using its original recording: it can raise separate questions about the composition, lyrics, and recording. The High Court’s reasoning recognized Ilaiyaraaja’s right in the musical work, but a license limited to that right did not authorize the proposed use of the lyrics or the original sound recording. A party seeking to use a song therefore needs to establish that its permissions cover the particular rights and materials involved, rather than assume that permission from one contributor clears every layer.
A related case is separate
In a separate Saregama dispute, a Delhi High Court judgment dated 1 July 2026 also distinguished the composer’s rights in musical composition from rights in lyrics and sound recordings. It is not part of the procedural chain in the “En Iniya Pon Nilave” case. Read that separate judgment.
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