Copy right film case stayed N Senthil.kumar judge for plaintiff advt Ramesh Ganabathy ipr HIGH COURT OF JUDICATURE AT MADRAS (Ordinary Original Civil Jurisdiction) C.S (COMM DIV) No. of 2025 RS Infotainment Rep by its Authorized Signatory Mr. T. Rajiv

IN THE HIGH COURT OF JUDICATURE AT MADRAS
(Ordinary Original Civil Jurisdiction)
C.S (COMM DIV) No. of 2025

RS Infotainment
Rep by its Authorized Signatory Mr. T. Rajiv
Flat No.5, Door No. 16, Bhagavandham Street,
T Nagar, Chennai – 600 017. …Plaintiff
vs.
1. Mini studio LLP
Rep by its Designated Partner Mr. S. Vinod Kumar
Plot no 20, Krishnapria Mariamman Koil Street,
MA Chidambaram Nagar, Ramapuram,
Chennai- 600 089

2. The Hotstar (Disney Star)
Kochar Jade, 7th, 8th, 9th and 10th Floor,
Plot no. SP 22, Thiruvika Industrial Estate,
Guindy, Chennai, Tamil Nadu- 600032 …Defendants

PLAINT FILED UNDER ORDER VII RULE 1 OF THE CODE OF CIVIL PROCEDURE 1908 R/W ORDER IV RULE 1 OF O.S. RULES R/W SECTION 17, 51, 55 & 62 OF COPYRIGHTS ACT 1957

PLAINTIFF: –

The Plaintiff is RS Infotainment, Rep by its Authorized Signatory Mr. T. Rajiv S/o. Thangavelu, aged about 41 years having address at Flat No.5, Door No.
16, Bhagavandham Street, T Nagar, Chennai – 600 017.
The address for service of all notices and processes of this Hon’ble Court on the Plaintiff is that of his Counsel The address for service on the Plaintiff is that of their Counsel Mr. Ramesh Ganapathy, Ms. Subashini I.M, Mrs. Kavya. R.B, Mr. Tharun Rajan. A.S, Santhiya. V and Oveya. S of M/s. Mission Legal, “Rahmat Manzil”, 1st Floor, No. 105, Armenian Street, Chennai, 600001.

DEFENDANTS: –
The 1st Defendant is Mini studio LLP, Rep by its Designated Partner Mr. S. Vinod Kumar having their office at Plot no 20, Krishnapria Mariamman koil
Street, Ma Chidambaram nagar, Ramapuram, Chennai- 6000 89

The 2nd Defendant is The Hotstar (Disney Star), having their office at Kochar Jade, 7th, 8th, 9th and 10th Floor, Plot no. SP 22, Thiruvika Industrial Estate, Guindy, Chennai, Tamil Nadu 600032

The address for service on Defendant No. 1 and Defendant No. 2 is the same as above, and the summons may be served on them at the same address given above through the District Munsif Court, Poonamalle and through this Hon’ble Court respectively.

THE PLAINTIFF SUBMIT AS FOLLOWS: –

1. It is submitted that the Plaintiff is a prominent production house in the South Indian film industry, which has garnered significant recognition since its inception in 2010. With a portfolio of critically acclaimed films, such as Vinnaithandi Varuvaya, KO, Muppozhudhum Un Karpanaigal, and Neethaane En Ponvasantham, the Plaintiff has consistently produced successful and impactful films across multiple languages including Tamil, Telugu, Kannada, and Hindi.
2. Following are the list of movies produced by the Plaintiff:
S.No Movie name Language Release year
1 Vinnaithandi Varuvayaa Tamil 2010
2 KO Tamil 2011
3 Rangam Telugu 2011
4 Ekk Deewanna Tha Hindi 2012
5 Muppozdhum Un
Karpanaigal Tamil 2012
6 Nirantharam nee Oohale Telugu 2012
7 Neethane En Ponvasantham Tamil 2012
8 Yamirukka Bayamey Tamil 2014
9 Namo Bhootama Kannada 2014
10 Yaan Tamil 2014
11 KO – 2 Tamil 2016
12 Kavalai Vendam Tamil 2016
13 Veera Tamil 2018
14 Viduthalai Part 1 Tamil 2023
15 Viduthalai Part 2 Tamil 2024
16 Mandaadi Tamil Under Production

3. It is submitted that as per Section 2(d)(v) of the Copyright Act, 1957, the term “author” in relation to a cinematograph film or sound recording refers to the producer of the film. The Plaintiff is the producer of Vinnaithandi Varuvaya (VTV), in collaboration with Escape Artists Motion Pictures, represented by Madan, under a Joint Venture Agreement dated 16th February 2009. As the producer, the Plaintiff holds all rights, including reproduction, adaptation, and public communication, under Sections 14 and 17 of the Copyright Act. The film VTV was re-released on 5th February 2022 and continues to be exhibited in VR Mall PVR Cinemas for over 1400 days.

4. It is submitted that Under Section 17 of the Copyright Act, the Plaintiff, as the producer, is the first owner of the work, unless there is a written agreement assigning the copyright to another party. In accordance with Section 14, the Plaintiff enjoys exclusive rights to reproduce, adapt, and communicate the work to the public. Additionally, the Plaintiff holds inalienable moral rights under Section 57, which protect the integrity of the work from any distortion, mutilation, or modification that could harm the Plaintiff’s reputation or honor.

5. It is a well established fact that numerous broadcasters, television networks and public media, digital platforms routinely utilize the plaintiff’s musical works for commercial exploitation, Under settled principles of copyright law, any person or entity seeking to use such protected works for commercial benefit, public exploitation, or business gains is legally obligated to obtain the necessary and appropriate permissions, licenses or sanctions directly from the Plaintiff as the rightful owner and creator of these works. The failure to secure such proper authorization constitutes unauthorized usage and infringement of the Plaintiff’s exclusive rights over his musical compositions and sound recordings.

6. It is submitted that the Plaintiff recently discovered that scenes and background music from Vinnaithandi Varuvaya were unlawfully incorporated into the Tamil film Aaromaley, which was written and directed by Sarang Thiagu and produced by S. Vinod Kumar under the
Mini Studi LLP banner. The film was released in theatres on 7th November 2025. The Plaintiff asserts that these scenes and background music were used without authorization. The first Defendant has exploited these scenes and background music in a covert and deceptive manner, engaging in digital distribution without informing the Plaintiff or obtaining the requisite consent.

7. It is submitted that the Plaintiff continues to assert his moral rights under Section 57 of the Copyright Act for Vinnaithandi Varuvaya. The first Defendant’s unauthorized exploitation of the Plaintiff’s work through commercial distribution across theatres and OTT platforms is a direct infringement of these rights. The unauthorized use of the Plaintiff’s work not only violates the Plaintiff’s economic rights (as set out under Section 14) but also undermines his moral rights by modifying, adapting, or presenting his work in ways that may conflict with the original artistic vision. By generating revenue from the unauthorized use of these scenes and background music the first Defendant has failed to acknowledge the Plaintiff’s rights, thereby committing a continuous violation of copyright law that demands immediate judicial intervention.

8. It is submitted that the first Defendant continues to engage in unlawful activities, including digital modification, exploitation, and remastering of the Plaintiff’s work. These actions constitute a deliberate and ongoing violation of the Plaintiff’s copyright and moral rights, particularly under Sections 14, 17, and 57 of the Copyright Act. The Defendant’s refusal to halt these activities or negotiate proper licensing demonstrates bad faith and a clear intent to infringe upon the Plaintiff’s rights. This ongoing infringement warrants immediate legal action to protect the Plaintiff’s statutory and moral rights under the Copyright Act.

9. In light of the above facts and circumstances, Plaintiff is constrained to file the present suit.
10. The cause of action for the present suit arose when the Plaintiff discovered that the first Defendant had unlawfully included scenes and background music from the Plaintiff’s copyrighted film, Vinnaithandi Varuvaya (“VTV”), in the Tamil film Aaromaley, which was released on 7th November 2025. The first Defendant’s unauthorized use of these scenes and background music occurred without any consent or licensing from the Plaintiff, thereby infringing upon the Plaintiff’s exclusive rights as the copyright holder. Despite the Plaintiff being the sole producer and copyright owner of VTV, the first Defendant proceeded with the digital exploitation of these scenes and background music through movie theatres and OTT platforms, generating commercial benefits while neglecting to seek or secure the necessary permissions. This act of unauthorized exploitation, carried out in secrecy and bad faith, directly violates the Plaintiff’s moral and economic rights under the Copyright Act, 1957, thereby giving rise to this legal action. The cause of action is continuing in nature, as the infringing film Aaromaley is presently being exhibited in theatres across various locations, thereby resulting in ongoing and continuous violation of the Plaintiff’s copyright and moral rights.

11. The Plaintiff states that, when the infringement of Copyright is ongoing and owing to the urgent interim reliefs contemplated by the Plaintiff, it can be exempted to comply with the institution of pre suit mediation process as per Section 12A of the Commercial Courts Act, 2015.

12. This Hon’ble High Court has jurisdiction to entertain, try, and adjudicate the present suit as the Plaintiff is carrying on business and/ working for gain at in Chennai Flat No.5, Door No. 16, Bhagavandham Street, T Nagar, Chennai – 600 017 within the territorial jurisdiction of this Hon’ble High Court. Substantial part of cause of action has also arisen within the jurisdiction of this Hon’ble High Court as the movie is running in theatres in various parts of Chennai. Therefore. in respect of infringement of copyright by the Defendants under Section 51, this Hon’ble Court has jurisdiction under Section 62 of the Copyrights Act, 1957. Therefore, this Hon’ble Court has jurisdiction to entertain and try the suit.

13. The subject matter of the suit seeking relief against the Defendants for
Copyright Infringement is a “Commercial Dispute” as defined under Section 2(1)(c)(xvii) of the Commercial Courts Act, 2015 read with proviso 1 to Section 7 of the Commercial courts Act, 2015 as the present suit is filed for acts of Copyright Infringement. Owing to the subject matter of the suit and the fact that urgent interim reliefs are being contemplated and prayed, the Plaintiff is entitled to initiate this suit without pursuing the remedy of pre-institution mediation as contemplated under Section 12A of the Commercial Courts Act, 2015.

14. The Plaintiff submits that they have approached this Hon’ble High Court with utmost diligence and that there has been no delay and the suit is filed well within the limitation.

15. The Plaintiff reserve their right to amend the pleadings and file further documents in support of their pleadings with the prior leave of this Hon’ble Court from time to time.

16. It is submitted that the Plaintiff values the above suit for the purpose of court fee and Jurisdiction as follows:

a) Prayer for permanent injunction restraining the Defendants from infringing the copyright of the Plaintiff. Rs. 2000/-
Court fee paid thereon u/s. 27(b) of the Tamil Nadu Court Fees & Suits Valuation Act,
XIV, 1955 Rs. 60/-
b) Prayer for permanent injunction restraining the Defendants from releasing the film “Aaromaley” through any digital or OTT platform, particularly Disney Hotstar due to the Plaintiff’s apprehension of imminent copyright infringement. Rs. 2000/-
Court fee paid thereon u/s. 27(b) of the Tamil Nadu Court Fees & Suits Valuation Act,
XIV, 1955
Rs. 60/-
c) Prayer of account valued at
Court fee paid thereon u/s. 35(1) of the Tamil Nadu Court Fees & Suits Valuation Act,
XIV, 1955
Rs. 1000/-

Rs. 30/-
TOTAL VALUE OF THE SUIT Rs. 5000/-
TOTAL COURT FEES PAID Rs. 150/-
17. The Plaintiff herein prays that this Hon’ble Court may be pleased to grant a judgment and decree on the following terms:
a. A permanent injunction restraining the Defendants, Directors, Partners, all their principal officers, staff, men, agent, servants, successors, assigns in business, representatives and any other person from infringing the copyright of the Plaintiff by using scenes and background music from the film “Vinnaithandi Varuvaya” (VTV), and thereby restraining the Defendants from in any manner infringing the copyright of the Plaintiff and thus render justice.

b. A permanent injunction restraining the Defendants, Directors,
Partners, all their principal officers, staff, men, their agents, affiliates, representatives, or anyone actiong on their behalf, from releasing, publishing, communicating to the public, streaming, exhibiting the scenes and background music from the film “Vinnaithandi Varuvaya” (VTV) in the film “Aaromaley” through any digital or OTT platform, particularly in Disney Hotstar, in any matter whatsoever;

c. A Preliminary Decree be passed in favour of the Plaintiff directing the Defendants to render a true and faithful accounts of all profit made by them using the scenes and background music from Plaintiff’s film and a final decree be passed in favour of the Plaintiff for the amount of profit thus found to be have been made by the Defendants, together with interest, after the Defendant has rendered accounts.

d. for the costs of the Suit; and

e. Pass such further Orders as this Hon’ble Court may deem fit and appropriate considering the facts and circumstances of the case and thus render justice.
Verified at Chennai this the 11th day of November 2025

COUNSEL FOR THE PLAINTIFF PLAINTIFF

VERIFICATION
I, Mr. T. Rajiv S/o. Thangavelu, aged about 41 years having address at Flat No.5, Door No. 16, Bhagavandham Street, T Nagar, Chennai – 600 017, do hereby declare that the facts stated above in paragraphs 1 to 17 are true and correct to the best of my knowledge, belief and information and signed at Chennai.
Verified at Chennai this the 11th day of November 2025

PLAINTIFF

LIST OF DOCUMENTS FILED BY THE PLAINTIFF UNDER ORDER XI RULE 1 (1) OF C.P.C AS AMENDED BY THE ACT 4 OF 2016
SL.NO DATE DESCRIPTION NATURE OF DOCUMENTS
1. 16.02.2009 Joint Venture Agreement between Plaintiff and Escape
Artists Motion Pictures Photocopy
2. 16.02.2009 Agreement between Plaintiff and Director of VTV Mr. Gautam Vasudev Menon Photocopy
3. 11.02.2010 Sensor Certificate Photocopy
4. 07.11.2025 Board Resolution authorizing Mr. T. Rajiv Photocopy

Verified at Chennai this the 11th day of November 2025

PLAINTIFF
VERIFICATION
I, Mr. T. Rajiv S/o. Thangavelu, aged about 41 years having address at Flat No.5, Door No. 16, Bhagavandham street, T Nagar, Chennai – 600 017, do hereby declare that the above-mentioned list of documents is true and correct to the best of my knowledge, belief and information and signed at Chennai.
Verified at Chennai this the 11th day of November 2025

PLAINTIFF
STATEMENT OF ADDRESS FILED UNDER ORDER VI RULE 14(A) OF CIVIL PROCEDURE CODE
1. Name and Address of the Plaintiff : RS Infotainment
Rep by its Authorized Signatory Mr. T. Rajiv
Flat No.5, Door No. 16,
Bhagavandham Street, T Nagar, Chennai – 600 017.
2. Address for service of the Plaintiff : Mr. Ramesh Ganapathy, Ms.
Subashini I.M, Mrs. Kavya. R.B, Mr.
Tharun Rajan. A.S, Santhiya. V and

2. Name and Address of the 1st Defendant
Oveya. S having office at M/s.
Mission Legal, “Rahmat Manzil”, 1st
Floor, No. 105, Armenian Street, Chennai, 600001.
: Mini studio LLP Rep by its Designated Partner Mr. S. Vinod

Kumar
Plot no 20, Krishnapria Mariamman
Koil Street, MA Chidambaram Nagar, Ramapuram, Chennai- 600
089

3. Name and Address of : The Hotstar (Disney Star) the 2nd Defendant Kochar Jade, 7th, 8th, 9th and 10th Floor, Plot no. SP 22, Thiruvika Industrial Estate, Guindy, Chennai, Tamil Nadu- 600032.
4. Address for service of : Same as stated above respectively the Defendants

Verified at Chennai this 11th day of November 2025

COUNSEL FOR PLAINTIFF PLAINTIFF VERIFICATION
I, Mr. T. Rajiv S/o. Thangavelu, aged about 41 years having address at Flat No.5, Door No. 16, Bhagavandham street, T Nagar, Chennai – 600 017, do hereby declare that the above-mentioned statement of address is true and correct to the best of my knowledge, belief and information and signed at Chennai.

Verified at Chennai this 11th day of November 2025

PLAINTIFF

MEMO OF VALUATION FILED UNDER ORDER VII RULE 1(1) OF C.P.C
a) Prayer for permanent injunction restraining the Defendants from infringing the copyright of the Plaintiff.
Valued at Court fee paid thereon u/s. 25(c)of the Tamil Nadu Court Fees & Suits
Valuation Act, XIV, 1955. Rs. 2000/-

Rs. 60/-
b) Prayer for permanent injunction restraining the Defendants from releasing the film “Aaromaley” through any digital or OTT platform, particularly Disney Hotstar due to the Plaintiff’s apprehension of imminent copyright infringement
Valued at Court fee paid thereon u/s. 27(b)of the Tamil Nadu Court Fees & Suits
Valuation Act, XIV, 1955. Rs. 2000/-

Rs. 60/-
c) Prayer of account valued at
Court fee paid thereon u/s. 35(1) of the
Tamil Nadu Court Fees & Suits Valuation
Act, XIV, 1955 Rs. 1000/-
Rs. 30/-
TOTAL VALUE OF THE SUIT

TOTAL COURT FEES PAID Rs. 5000/-

Rs. 150/-

Verified at Chennai on this the 11th day of November 2025.

COUNSEL FOR THE PLAINTIFF PLAINTIFF

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