Delhi HC Affirms Satyajit Ray’s Copyright Ownership of Bengali Film ‘Nayak’

The Delhi High Court has upheld the decision of a single judge, affirming that renowned filmmaker Satyajit Ray is the first copyright owner of the 1966 Bengali film “Nayak” because he wrote the screenplay for the movie.

A division bench of Justice Yashwant Varma and Justice Tushar Rao Gedela ruled that Section 17 of the Copyright Act is directly applicable in this instance, establishing that the copyright for the screenplay belongs to the author of the literary work, which in this case is Satyajit Ray.

“While the plaintiff/appellant may have served as the film’s producer for ‘Nayak,’ it could not have claimed an overriding right in the screenplay considering the explicit language and intent of Section 13(4) of the Act. Acknowledging the presence of copyright in the screenplay’s author, any entitlement the plaintiff/appellant might assert over the cinematographic work would not have encroached upon or diluted the rights of the screenplay’s author,” the order reads.

This conclusion aligns with the decision reached on May 23, 2023, by Justice C Hari Shankar, who also confirmed that Ray possessed the right to adapt the screenplay into a novel. The court further noted that following Ray’s passing, this right could be transferred by his successors, including his son and others inheriting such rights.

As a result, the court dismissed the plea brought forth by the film’s producers, RDB and Co (plaintiff), who had sought to prevent publishing house HarperCollins (defendant) from releasing the novelization of the screenplay.