Delhi High Court fines Paramvah Studios Rs 25 lakh for unauthorised use of songs in 'Bachelor Party'

The Delhi High Court has directed actor Rakshit Shetty’s Paramvah Studios to pay a total of Rs 25 lakh for using two songs in the film Bachelor Party without permission.

While the court chose not to pursue jail time for Rakshit, it did impose a specific Rs 5 lakh fine to "purge" or clear the contempt of court charges. This penalty comes after the studio failed to strictly follow the court’s previous directions regarding the unauthorised music.

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

"In any event, the use of the Original Works in the Impugned Film was not minimal, as the song “Omme Ninnanu” was incorporated for a 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. 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.

"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, Defendants Nos. 1 and 2 are directed to remit an exemplary cost of Rs 500,000/- to the Plaintiff within two weeks to purge the contempt committed."

MRT Music claimed they own the rights to both songs and backed it up with a legal agreement, called an assignment deed, that they had signed back 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.

Released in 2024, following the film's theatrical run and its digital streaming, the Court took action regarding the music rights. On August 12, 2024, a judge ordered the production house to put down a Rs 20 lakh deposit within four weeks and immediately pull the disputed scenes or songs from the film.

The defendants failed to meet the court-ordered deadline and continued to use the disputed songs, which forced MRT Music to file a contempt case against them. Although the studio did eventually deposit the Rs 20 lakh while the case was ongoing, the initial delay was seen as a serious violation of the court's authority.

The judges rejected the idea that the ownership had lapsed under Section 19(4). They noted that because MRT was still making the songs available online, the rights hadn't 'returned' to the original creators. As the music is still being used, the 2020 contract remains valid and in full effect.

Rakshit 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 said 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 Rs 20 lakh previously deposited by Shetty and Paramvah Studios to MRT Music.

2) The Court imposed an additional Rs 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 and Shivansh Tiwari from Ira Law and Advocates Ritik Raghuvanshi, Shrudula Murthy and Rishika Aggarwal.

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