Copyright in Cinematograph Films – Ownership, Rights and Exploitation

Few creative works demand as much capital, coordinate as many individual contributions, or generate as much commercial activity as a cinematograph film. A feature film involves the labour of writers, directors, composers, lyricists, performers, cinematographers, editors, sound designers, visual effects artists and hundreds of others whose individual creative contributions are assembled, over months or years, into a single unified work. The question of who owns the copyright in that work  and what that ownership entails  is not merely an academic exercise. It determines who may authorize the reproduction, broadcast and streaming of the film, who collects the revenue generated by those authorizations, how disputes between contributors are resolved and what rights individual creative authors retain after their contributions have been incorporated into the finished work.

Indian copyright law’s treatment of cinematograph films is distinctive, structurally coherent and in certain respects significantly more protective of the film producer’s position than the comparable frameworks of the United Kingdom or the United States. The Copyright Act, 1957, as amended most recently in 2012, gives the producer of a cinematograph film a comprehensive and independent bundle of exclusive rights in the film as a whole, while simultaneously preserving certain individual rights  particularly the rights of authors and performers in their constituent contributions. The management of the tension between these two sets of rights has generated some of the most important and contested decisions in Indian intellectual property jurisprudence.

This article offers a comprehensive examination of copyright in cinematograph films under Indian law  moving through the statutory definition of the work, the vesting of ownership in the producer, the specific content of the film copyright, the rights retained by individual authors and performers, the assignment and licensing of film rights, exploitation mechanisms in the contemporary market and the landmark cases that have shaped this field.

The Statutory Definition – What is a Cinematograph Film

Section 2(f) of the Copyright Act, 1957 defines “cinematograph film” as any work of visual recording on any medium produced through a process from which a moving image may be produced by any means and includes a sound recording accompanying such visual recording. The definition further provides that “cinematograph” shall be construed as including any work produced by any process analogous to cinematography, including video films.

The breadth of this definition is deliberate and consequential. A cinematograph film under Indian law is not limited to celluloid or any particular recording medium it encompasses digital files, video recordings, animated works produced through computer-generated imagery and any other visual recording from which moving images may be produced. The inclusion of the accompanying sound recording within the definition of the cinematograph film is significant: it means that the soundtrack, including the songs and background score, is treated as an integral component of the film for the purpose of the film copyright, even though it also attracts independent protection as a sound recording under Section 13(1)(c).

The definition was substantially amended in 1994 to achieve this technology-neutral formulation. The pre-1994 definition had referred to the sound track as something that was “included” in the cinematograph film in a more limited sense; the current definition makes the accompanying sound recording a constituent element of the film itself. This amendment had significant implications for the rights of composers and lyricists whose works are incorporated in film soundtracks  implications that the Supreme Court had addressed in principle in the Eastern India Motion Pictures Association case of 1977 and that the Delhi High Court examined at length in the IPRS v. Aditya Pandey decision of 2011.

The width of Section 2(f) means that the cinematograph film category in Indian law encompasses works that other legal systems treat as distinct categories — broadcast recordings, home videos, corporate films, documentary recordings, television series and even certain forms of animated digital content. Each of these attracts the full suite of protections available to a cinematograph film under the Act.

Copyright Subsistence in Cinematograph Films

Section 13(1)(b) of the Copyright Act provides that copyright shall subsist throughout India in cinematograph films. The conditions for copyright subsistence are set out in Section 13(2): in the case of a published work, the film must be first published in India or if first published outside India, the producer must be a citizen of India at the date of publication or in the case of a deceased producer, must have been a citizen of India at the time of death.

Section 13(3) provides two conditions under which copyright shall not subsist in a cinematograph film. First, if a substantial part of the film is an infringement of the copyright in any other work, no copyright subsists in the film. This provision addresses the problem of films built substantially upon unauthorized use of pre-existing copyrighted material  a film that incorporates a substantial portion of a prior work without the rights holder’s consent cannot itself attract film copyright protection. Second, no copyright subsists in a sound recording made in respect of a literary, dramatic or musical work if, in making that recording, copyright in such work has been infringed.

Section 13(4) is among the most important provisions in the entire copyright framework as it relates to films. It provides that the copyright in a cinematograph film or a sound recording shall not affect the separate copyright in any work of which a substantial part forms the basis of the film or recording. This is the statutory declaration that the film copyright and the copyrights in constituent works are independent and co-existing. The film producer’s copyright in the film as a whole does not extinguish or absorb the copyright in the screenplay, the music, the lyrics, the dialogue, the photographs or any other original work that has been incorporated in the film. Each retains its individual copyright identity. The management of these co-existing copyrights who owns them, who can enforce them and against whom  is the central challenge of film copyright law in India.

Authorship and First Ownership – The Producer’s Position

The most significant structural feature of Indian film copyright law is the vesting of authorship and first ownership in the producer of the film. Section 2(d)(v) of the Copyright Act defines “author” in relation to a cinematograph film as the producer. Section 2(uu) defines “producer” in relation to a cinematograph film or sound recording as the person who takes the initiative and responsibility for making the work.

The identification of the producer as the author of a cinematograph film is a departure from the intuitive understanding of authorship as a creative rather than organizational and financial function. In other jurisdictions, particularly in Europe following the harmonization of film authorship rules by the EU Term Directive, the principal director is recognized as an author of the film alongside or in preference to the producer. In India, no such recognition has been accorded to directors by statute and the producer remains the sole deemed author and first copyright owner of the film as a whole.

The rationale for this approach lies in the economics of film production. A film is not the creative expression of a single individual – it is a complex collaborative enterprise funded and coordinated by the producer, who bears the financial risk of production, assembles the creative team, acquires the underlying rights and takes responsibility for the work’s completion and release. The law’s attribution of authorship to the producer reflects this organizational and financial centrality, even at the cost of a certain creative distortion  for in many if not most films, the director’s creative vision is the dominant force shaping the work as a cinematic experience.

Section 17 of the Copyright Act provides that the author of a work shall be the first owner of the copyright therein, subject to the provisos that follow. Proviso (b) to Section 17 provides that where a work is made by the author in the course of their employment under a contract of service or apprenticeship, the employer shall, in the absence of any agreement to the contrary, be the first owner of the copyright. Proviso (c) provides that where a work is made by an author in pursuance of a commission or a contract with another party, the party giving the commission shall, in the absence of agreement to the contrary, be the first owner. Together, these provisos ensure that works created by employees or commissioned authors for the film – including scripts, scores, lyrics and cinematographic sequences vest in the producer as first owner, absent contrary agreement.

The interaction between the producer’s deemed authorship under Section 2(d)(v), the proviso to Section 17 and the separate copyrights preserved by Section 13(4) creates a complex layered ownership structure. In the case of music composed and lyrics written specifically for a film by persons employed or engaged by the producer, the producer becomes the first owner of the copyright in the musical and literary works as well as the film itself. This was the basis of the Supreme Court’s ruling in Indian Performing Right Society v. Eastern India Motion Pictures Association (1977) that a film producer who commissions music and lyrics for a film becomes the first owner of those works under Section 17(b) or (c) and can therefore authorize their performance in public as part of the film without the composer’s or lyricist’s further consent.

The Exclusive Rights in a Cinematograph Film

Section 14(d) of the Copyright Act sets out the exclusive rights that constitute copyright in a cinematograph film. These are the right to make a copy of the film, including a photograph of any image forming part thereof; the right to sell or give on hire or offer for sale or hire, any copy of the film regardless of whether such copy has been sold or given on hire on earlier occasions; and the right to communicate the film to the public.

Each of these rights deserves examination. The right to make a copy of the film is the primary reproduction right – it covers the duplication of the film in any medium, whether physical or digital. The creation of a DVD master, the encoding of the film as a digital file, the creation of a streaming-quality transcode and the making of a theatrical print are all exercises of the reproduction right. Unauthorized copying of a film – whether through optical disc duplication, digital ripping or torrent-based sharing – constitutes infringement of this right.

The right to sell or give on hire includes the physical distribution of the film through home video and the expression “regardless of whether such copy has been sold or given on hire on earlier occasions” addresses the exhaustion question in relation to film copies. Unlike in some other jurisdictions, the sale of a copy of a film does not exhaust the right to control subsequent hiring of that copy- the copyright owner retains the right to prevent the hired-out use of sold copies. This is a deliberate policy choice reflecting the commercial sensitivity of the rental market for films.

The right to communicate the film to the public is the most commercially significant of the three in the contemporary media landscape. Section 2(ff) defines “communication to the public” broadly as making any work available for being seen or heard or otherwise enjoyed by the public directly or by any means of display or diffusion other than by issuing copies of the work, regardless of whether any member of the public actually sees, hears or otherwise enjoys the work so made available. The explanation to Section 2(ff) clarifies that communication through satellite or cable or any other means of simultaneous communication to more than one household or place of residence – including residential rooms of any hotel or hostel – is deemed to be communication to the public.

This definition is technology-neutral and deliberately expansive. Theatrical exhibition, television broadcast, cable retransmission, satellite transmission, internet streaming, on-demand digital delivery and any future technology of public communication are all within the communication right. The producer who holds the communication right therefore controls the entire chain of public exploitation of the film across all present and future platforms – a position of extraordinary commercial power in the current market, where subscription video-on-demand platforms, over-the-top broadcasters and social media all compete for the right to stream Indian film content to global audiences.

The Term of Copyright in Cinematograph Films

Section 26 of the Copyright Act provides that copyright in a cinematograph film shall subsist until sixty years have elapsed after the beginning of the calendar year next following the year in which the film is published. Publication in this context refers to the first making available of the film to the public, which in the case of theatrical release is the date of first exhibition.

The sixty-year term for films is shorter than the seventy-year post-mortem auctoris term that applies to literary, dramatic, musical and artistic works. This reflects the different basis of film copyright duration  it runs from publication rather than from the author’s death, consistent with the film being treated as a corporate rather than a personal creative work. For a film released in 2025, the copyright would subsist until the end of the calendar year 2085. For classic films of the 1950s and 1960s, many of which are now approaching or within their copyright term, the interaction between the film copyright and the potentially still-subsisting copyrights in underlying works creates complex clearance challenges.

Rights Retained by Authors of Underlying Works

The most practically contested area of film copyright law in India is the extent to which authors of works incorporated in a film retain rights that they can independently exercise against users of the film or its elements. The statutory framework, as described above, appears to grant comprehensive rights to the producer while preserving the separate copyrights of individual authors. The practical question is what, after the producer’s rights are fully accounted for, the individual author retains that has independent commercial value.

The Supreme Court in the Eastern India Motion Pictures Association case held that a composer or lyricist who authorizes the incorporation of their work in a film cannot prevent the film owner from exhibiting the film  including its acoustic content  in public or from communicating the film by radio diffusion. However, the composer retains the right to perform the work independently in public for profit, other than as part of the cinematograph film. Justice Krishna Iyer’s formulation in that case drew the line precisely: showing the film, including its songs, is the film owner’s right; extracting the songs and playing them separately is the composer’s reserved domain.

The 2012 amendment introduced a significant modification to this framework in the context of royalties. Section 18 of the amended Act provides that where an author of a literary or musical work incorporated in a cinematograph film assigns the copyright in such work to the film producer, the assignment shall not affect the author’s right to receive an equal share of the royalties and consideration payable for the utilization of such work in any form other than as part of the cinematograph film. Additionally, the royalties for utilization of the work in any form other than the cinematograph film shall be shared equally between the author and the assignee.

This provision represents a substantial legislative intervention in the allocation of value between film producers and creative authors. Prior to the amendment, a composer or lyricist who had assigned their copyright to the film producer had no residual claim to royalties from any exploitation of the work  the assignment transferred the full economic interest. After the amendment, even where the copyright has been fully assigned, the author is entitled to an equal share of royalties from exploitation outside the film context  including streaming, broadcast licensing, ring tone revenues and any other standalone exploitation of the songs. This right cannot be contractually waived in advance and any agreement to the contrary is void under Section 18 as amended.

The Director’s Copyright Question

Indian copyright law’s silence on the director’s authorship of a cinematograph film has been a persistent source of debate. In European law, the principal director is recognized as a co-author of the film under the Term Directive’s harmonization provisions and this recognition carries with it moral rights and residual economic entitlements that the director retains even after the film is completed and commercially released.

Indian law recognizes no such authorship in the director. The director creates the film  makes the creative choices that determine its visual language, its performances, its rhythm and its meaning  but holds no copyright in the film as a whole by virtue of that creative act. The director’s legal relationship with the film is contractual, not proprietary. Directors in India typically work under employment contracts or service agreements with the producer and whatever rights they have in connection with the film’s exploitation arise from contract rather than from the Copyright Act.

This position has been criticized by directors, particularly those whose films have generated substantial revenues through streaming deals and satellite licensing in the years following their theatrical release. The 2012 amendment’s royalty-sharing provisions apply to authors of literary and musical works but not expressly to directors  a lacuna that reflects the legislative prioritization of composers and lyricists, who had been most visibly exploited by the pre-amendment framework, over other creative contributors.

The absence of directorial copyright in India has also implications for moral rights. Section 57 of the Act protects the moral rights of the “author” of a work. Since the director is not recognized as the author of the film for copyright purposes, the director has no moral rights under Section 57 in respect of the film as a whole. A director who objects to a film being re-edited, colorized or dubbed in a manner that distorts their creative vision has no statutory remedy under Section 57 –  their recourse, if any, must be sought in contract. This is a significant gap relative to international standards and one that the Indian film industry’s growing global profile makes increasingly visible.

Ownership Disputes – Key Cases

Indian Performing Right Society v. Eastern India Motion Pictures Association, AIR 1977 SC 1443 remains the foundational authority on the relationship between the film producer’s copyright and the rights of composers and lyricists. As discussed above, the Supreme Court’s ruling that the film producer acquires, through the provisos to Section 17, the right to communicate the film including its musical content without further authorization from the composer, established the primacy of the producer’s position in the Indian system. The decision has been criticized, qualified by the 2012 amendments and limited in its application by subsequent decisions, but it remains binding authority on the core structural question of first ownership.

The IPRS v. Aditya Pandey (2011) decision, discussed at length elsewhere on this platform, extended the Eastern MPA principle to the post-1994 sound recording regime and held that a broadcaster holding a licence from the sound recording owner need not obtain a separate licence from IPRS for the underlying musical and literary works when communicating the sound recording to the public. The decision’s treatment of the relationship between sound recording rights and underlying work rights is essential reading for any understanding of music licensing in the film context.

Mannu Bhandari v. Kala Vikas Pictures Pvt. Ltd., AIR 1987 Delhi 13 involved a novelist who had licensed her work for adaptation into a film and subsequently objected to changes made to the film version. The Delhi High Court upheld the author’s right under Section 57 to restrain modifications to the adaptation that she considered prejudicial to her honour, holding that the author’s moral right of integrity persists even after the assignment of adaptation rights. This decision is significant for establishing that the assignment of film adaptation rights does not transfer the author’s moral rights under Section 57.

Tips Industries Ltd. v. Wynk Music Ltd. (2019) addressed the scope of the statutory licence under Section 31D of the Copyright Act and held that this provision, which allows broadcasters to communicate sound recordings under a compulsory licence, does not extend to on-demand streaming services. The Bombay High Court’s reasoning  that streaming is interactive and individuated communication rather than broadcasting to a simultaneous audience  has significant implications for the licensing of film content on subscription platforms.

Sholay Media and Entertainment Pvt. Ltd. v. Parag Sanghavi (2015) involved the iconic film Sholay and raised questions about the rights of the original producers’ successors to prevent unauthorized three-dimensional reproductions of characters from the film. The Delhi High Court recognized the right of the film’s copyright holders to protect against unauthorized merchandising of characters and images from the film, affirming that the film copyright extends to protection against commercial exploitation of distinctive visual elements.

Rupendra Kashyap v. Jiwan Publishing House Pvt. Ltd. (1996) addressed the literary copyright in a film screenplay and held that the author of a screenplay retains copyright in that work as an original literary work, independently of the film copyright vesting in the producer. This decision affirmed the principle of Section 13(4) that the film copyright does not absorb or extinguish the individual copyrights in constituent works in the specific context of the literary work underlying the film.

Assignment and Licensing of Film Rights

The exploitation of a cinematograph film’s copyright takes place through a combination of assignments and licences, structured to extract maximum value from each distinct market and medium. The Copyright Act’s provisions on assignment and licensing  Sections 18 to 30  apply to film copyright as to any other category, subject to the specific provisions and the 2012 amendments.

A full assignment of film copyright transfers all of the rights enumerated in Section 14(d) to the assignee. Assignments in the film industry are common and take several standard forms: the assignment of satellite broadcast rights to a television channel for a defined period; the assignment of digital rights to an OTT platform; the assignment of home video rights to a distribution company; and the assignment of theatrical distribution rights to a distributor for a defined territory.

Section 19 of the Act imposes formal requirements on assignments of copyright in any work. An assignment must be in writing and signed by the assignor or their authorized agent. It must specify the rights assigned, the duration and territorial extent of the assignment, the quantum of royalty payable and any revision, extension or termination clause. Section 19(8) provides that if the assignee fails to exercise the assigned rights within one year from the date of assignment, the assignment in respect of those rights is deemed to have lapsed. Section 19(9) provides that if the period of assignment is not specified, it shall be deemed to be five years. These provisions protect authors and original rights holders against indefinite assignments with no exploitation.

Section 19A, introduced by the 2012 amendment, provides a mechanism for the resolution of disputes arising from the assignment of copyright to a film producer. Where the assignee does not exercise the assigned rights within the agreed period, the Copyright Board may, on application by the assignor, pass an order revoking the assignment. This provision is designed to prevent the common industry practice of acquiring rights to block competition without any genuine intention to exploit the work.

Licensing of film rights, as distinct from assignment, is widely used for time-limited and territory-limited commercial arrangements. A licence does not transfer ownership of the copyright  it grants the licensee permission to exercise specified rights for a defined period. Theatrical distribution agreements, satellite broadcast agreements, digital platform deals and home video licensing arrangements are typically structured as licences for defined territories and periods, with the copyright remaining with the producer or the producer’s permanent assignee.

The OTT Revolution and Film Copyright Exploitation

The growth of over-the-top streaming platforms  Netflix, Amazon Prime Video, Disney+ Hotstar, ZEE5, SonyLIV and others  has transformed the economics of film copyright exploitation in India and created new legal questions that the Copyright Act, as currently drafted, was not designed to answer.

The acquisition of streaming rights to Indian films by OTT platforms involves the licensing of the communication right under Section 14(d)(iii)  the right to communicate the film to the public. For many films, particularly mid-budget and small-budget productions, OTT licensing has become the dominant revenue stream, often exceeding theatrical collections. For larger productions, day-and-date OTT releases  simultaneous theatrical and streaming launches  have become commercially viable, blurring the traditional window structure that had separated theatrical, satellite and digital rights.

The valuation and negotiation of OTT rights has given rise to new forms of dispute. Revenue sharing arrangements between producers and platforms, the definition of a “window” in an era of simultaneous multi-platform release, the application of the 2012 amendment’s royalty-sharing provisions to digital streaming revenues and the copyright implications of platform-exclusive content produced in co-production arrangements with OTT companies  all of these are live commercial and legal questions whose resolution will shape the exploitation of film copyright over the next decade.

The question of whether the exploitation of film content on OTT platforms requires separate licences from IPRS for the underlying musical works  the question at the heart of IPRS v. Aditya Pandey in the broadcast context  has not been definitively resolved for the streaming context. The Tips Industries decision, which held that on-demand streaming is not broadcasting within the meaning of the statutory licence under Section 31D, reinforced the need for direct licensing between music rights holders and OTT platforms for musical works. The application of the royalty-sharing provisions of the 2012 amendment to OTT revenues received by producers is a further unresolved question that is increasingly relevant as streaming revenues grow.

Piracy and Enforcement of Film Copyright

Cinematograph films are among the most heavily pirated categories of intellectual property in India. The combination of high production values, strong audience demand and the ease of digital reproduction makes films particularly vulnerable to large-scale infringement. The Copyright Act provides a range of civil and criminal remedies for film piracy and specific provisions address the particular forms of infringement most common in the digital environment.

Section 65A of the Act, introduced by the 2012 amendment, prohibits the circumvention of technological protection measures applied to a work, including films. The use of devices or software to bypass digital rights management systems protecting film content  whether for ripping DVDs, bypassing streaming access controls or circumventing watermarking systems  is prohibited and attracts civil and criminal liability.

The Copyright Act’s criminal provisions, under Sections 63 to 66, provide for imprisonment and fines for wilful infringement of copyright and related rights. Section 63B provides enhanced penalties for knowing use of infringing copies of computer programmes and Section 65 addresses the making or possession of plates or devices for making infringing copies. In the film context, camcording in theatres  the recording of films on handheld devices during theatrical exhibition  is a specific and persistent problem that the criminal provisions, in principle, address.

The Delhi High Court’s development of the dynamic injunction mechanism in UTV Software Communications Ltd. v. 1337X.to & Ors. (2019) has provided rights holders with a more effective tool for combating online film piracy through website blocking. Dynamic injunctions allow rights holders to extend blocking orders to mirror sites and proxy servers of blocked piracy websites without requiring fresh proceedings, addressing the practical problem that infringing platforms routinely reconstitute themselves at new domain addresses after blocking.

Copyright in Jointly Produced and Co-produced Films

The international co-production of films  a practice now widespread in the Indian industry, particularly for large-budget productions with international distribution ambitions  raises complex questions of copyright ownership and exploitation that the Copyright Act does not directly address.

In a typical co-production arrangement, two or more producers from different countries contribute creative and financial resources to a film’s production and share the resulting rights in proportions agreed by contract. The copyright in the resulting film may vest in both producers jointly or may be allocated by territory or by medium under the co-production agreement. The application of Section 13’s subsistence conditions to jointly produced works  particularly the citizenship and domicile requirements  can create uncertainty about the film’s copyright status in India where the Indian co-producer’s contribution is minimal.

Joint ownership of copyright under Indian law, governed by Section 30A and general principles, means that each joint owner may independently license the work for non-exclusive purposes but cannot independently assign the copyright or grant exclusive licences without the consent of the other joint owners. This rule has significant implications for co-produced films whose rights are held jointly, particularly where the co-producers subsequently disagree about exploitation strategy or terms.

Moral Rights in Film — The Unresolved Question

As discussed above, the director of a cinematograph film holds no copyright in the film as a whole under Indian law and therefore has no moral rights under Section 57 in respect of the film. The composer and lyricist, who do hold copyright in their contributions as literary and musical works, have moral rights under Section 57 in those contributions  a right affirmed in the Mannu Bhandari case and consistent with the general principles developed in the landmark Amarnath Sehgal v. Union of India (2005) decision in the context of visual art.

The practical consequence is that a film producer who re-edits, colorises, dubs into a different language or otherwise modifies a completed film does so without any legal obligation to the director — whose creative vision the film embodies — to seek consent or even notification. The director’s only recourse is contractual. In the absence of a specific contractual provision protecting the director’s creative integrity, the producer’s right to modify the film is unrestricted.

This position has attracted criticism from the Indian film directors’ community and has been raised in the context of discussions about the adequacy of the 2012 amendments. The recognition of directorial moral rights  either through statutory amendment or through an expansive judicial interpretation of “author” in Section 57 would bring Indian law into closer alignment with the international standard and provide meaningful protection to the creative authors whose vision gives Indian cinema its distinctive character.

Conclusion

Copyright in cinematograph films sits at the intersection of commerce, creativity and law in a manner that is more complex and more consequential than almost any other category of intellectual property. The producer’s comprehensive first ownership of the film copyright, derived from deemed authorship under Section 2(d)(v) and reinforced by the provisos to Section 17, provides the financial foundation upon which the Indian film industry’s elaborate system of rights exploitation is built. The independent copyrights of individual authors — composers, lyricists, screenwriters  preserved by Section 13(4) and increasingly protected by the royalty-sharing provisions of the 2012 amendment, ensure that the creative contributors whose work gives the film its value are not entirely subordinated to the producer’s commercial interests.

The challenges that remain  the director’s absence from the copyright framework, the unresolved application of royalty-sharing provisions to digital streaming revenues, the interaction between film copyright and the rights of performers and the adequacy of the enforcement framework against large-scale online piracy  are not peripheral. They go to the heart of how the Indian film industry, one of the largest and most creative in the world, will organize itself in the era of global streaming, digital distribution and artificial intelligence-assisted production.

The Copyright Act, 1957 has been amended repeatedly to keep pace with these developments, but the pace of technological and commercial change continues to outrun the legislative response. For practitioners, producers, creators and platforms operating in this space, the foundational framework described in this article is the starting point for every rights analysis  but it is rarely the end point.

References

  1. The Copyright Act, 1957, Sections 2(d), 2(f), 2(ff), 13, 14(d), 17, 18, 19, 26 — https://copyright.gov.in/Documents/CopyrightRules1958.pdf
  2. The Copyright (Amendment) Act, 2012 — https://copyright.gov.in/Documents/Amendment_Act2012.pdf
  3. Indian Performing Right Society v. Eastern India Motion Pictures Association, AIR 1977 SC 1443 — https://indiankanoon.org/doc/553674/
  4. The Indian Performing Right Society Ltd. v. Aditya Pandey & Anr., CS(OS) 1185/2006 (Delhi High Court, 2011) — https://indiankanoon.org/doc/1207507/
  5. Mannu Bhandari v. Kala Vikas Pictures Pvt. Ltd., AIR 1987 Delhi 13 — https://indiankanoon.org/doc/889479/
  6. Tips Industries Ltd. v. Wynk Music Ltd. (2019), Bombay High Court — https://bombayhighcourt.nic.in
  7. UTV Software Communications Ltd. v. 1337X.to & Ors., CS(COMM) 724/2017 (Delhi High Court, 2019) — https://delhihighcourt.nic.in
  8. Sholay Media and Entertainment Pvt. Ltd. v. Parag Sanghavi, CS(OS) 1892/2015 (Delhi High Court) — https://indiankanoon.org/doc/50984038/
  9. Rupendra Kashyap v. Jiwan Publishing House Pvt. Ltd., AIR 1996 Delhi 286 — https://indiankanoon.org/doc/1388633/
  10. Amarnath Sehgal v. Union of India, 117 (2005) DLT 717 (Delhi High Court) — https://indiankanoon.org/doc/1402532/
  11. Garware Plastics & Polyester Ltd. v. Telelink & Ors., AIR 1989 Bom 331 — https://indiankanoon.org/doc/1381311/
  12. Berne Convention for the Protection of Literary and Artistic Works — https://www.wipo.int/treaties/en/ip/berne/
  13. TRIPS Agreement — https://www.wto.org/english/docs_e/legal_e/27-trips.pdf
  14. WIPO Performances and Phonograms Treaty, 1996 — https://www.wipo.int/treaties/en/ip/wppt/
  15. Beijing Treaty on Audiovisual Performances, 2012 — https://www.wipo.int/treaties/en/ip/beijing/
  16. EU Council Directive 93/83/EEC (Satellite and Cable Directive) — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31993L0083

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