The Delhi High Court recently ordered Paramvah Studios, the production house spearheaded by Kannada actor-director Rakshit Shetty, to pay a total of ₹25 lakh for the unauthorised use of two songs in his Kannada film Bachelor Party. [MRT Music v. Paramvah Studios]

Justice Tejas Karia held the studio liable for copyright infringement and willful disobedience of court directions, rejecting the filmmakers' defence that the musical usage was too "minimal" to require a license.

"In any event, the use of the Original Works in the Impugned Film was not minimal as the song “Omme Ninnanu” was incorporated for substantial 31 seconds whereas the song “Nyaya Ellide” was used for 7 seconds. As per Section 14(d)(i)(A) of the Copyright Act, even a single photograph of any image forming part of the film is an exclusive right given to the copyright owner and, therefore, the Defendants could not have used even a single frame for even a second from the audio-visual of the song “Nyaya Ellide” without permission of the Plaintiff," the Court held.

The Court stopped short of sending Shetty to jail, instead asking him and Paramvah Studios to pay ₹5 lakh to purge contempt of its orders.

"However, upon consideration of the Affidavit dated 31.10.2025 submitted by Defendant Nos. 1 and 2 expressing regret for their actions, the Court is inclined to exercise leniency. Rather than imposing simple imprisonment on Defendant No. 2 for contempt of the Order dated 12.08.2024, Defendant Nos. 1 and 2 are directed to remit an exemplary cost of ₹5,00,000/- to the Plaintiff within two weeks to purge the contempt committed."

MRT Music, a music label, claimed ownership over the two songs, including their sound recordings and underlying literary and musical works, on the basis of an assignment deed executed in 2020.

The company alleged that the songs were used in Bachelor Party without obtaining a licence. One of the songs was played on a television in a scene, while the other was sung in a classroom sequence to support the narrative. The film was released theatrically in January 2024 and later made available on OTT platforms.

On August 12, 2024, the Court passed an interim order directing the defendants to deposit ₹20 lakh within four weeks and take down infringing content. However, they did not comply within the stipulated period and continued to exploit the works, leading MRT Music to initiate contempt proceedings.

The defendants subsequently deposited the amount during the course of the proceedings, but the delay in compliance formed the basis of the contempt action.

The Court rejected the lapse argument under Section 19(4), noting that MRT had continued to exploit the works, including on digital platforms. Since there was no evidence of non-use, the rights had not reverted and continued to subsist on the date of the suit.

Shetty and Paramvah Studios argued the use was "de minimis" (minimal), noting that "Nyaya Ellide" appeared for only 7 seconds and "Omme Ninnanu" for 31 seconds. However, the Court looked beyond the stopwatch to the creative intent behind the clips.

It shot down the argument that these uses were "incidental" or "irrelevant". Instead, the judge found that the songs were carefully selected to drive the movie's narrative.

The Court noted that the title "Nyaya Ellide" translates to "Where is the justice?". Choosing this specific song to play while the protagonist was suffering was deemed a deliberate creative decision to highlight his plight.

"This clearly shows that the use of Original Works was not merely incidental or irrelevant but was actually a conscious creative call taken to further the plot of the Impugned Film."

The Court concluded that because the songs were used for commercial gain and to match the script, they did not qualify for the "de minimis" exception.

The total financial mandate consists of two separate directions:

1) The Court directed the Registry to release the ₹20 lakh previously deposited by Shetty and Paramvah Studios to MRT Music.

2) The Court imposed an additional ₹5 lakh penalty because the filmmakers failed to meet the original 2024 deposit deadline.

MRT Music was represented by Senior Advocate Swathi Sukumar with Advocates Asavari Jain, Geetanjali Visvanathan, Shivansh Tiwari, Ritik Raghuvanshi, Shrudula Murthy, Rishika Aggarwal and Prathibha from Ira Law.

Paramvah Studios and others were represented by Senior Advocate J Sai Deepak with Advocates Meenakshi Ogra, Samrat S Kang and Vishnu Gambhir.

[Read Judgment]