Delhi HC Declines Interim Injunction on Mission Raniganj’s song ‘Jalsa’

The Delhi High Court has declined to issue an interim order restraining the use of the song “Jalsa” by singer Satinder Pal Singh Sartaaj in the upcoming film “Mission Raniganj,” after he deposited Rs 25 lakhs with the court.

This decision came in response to a suit filed by Saga Music Private Limited, which sought a permanent injunction against Sartaaj and others from using the song in the Akshay Kumar-starrer movie. Saga Music claimed ownership of the song’s rights based on an agreement dated August 16, 2022.

However, it was revealed that Sartaaj had assigned all the rights of the song to Sony Music Entertainment India Private Limited in 2014 for perpetuity.

A bench of Justice Pratibha M Singh declined to grant the interim injunction sought by Saga Music, provided that Sartaaj makes the ₹25 lakhs deposit with the Court. The Court observed that this case highlighted the complex and precarious position of artists, film producers, and rights management companies when multiple agreements are executed for the same work.

During the hearing, the Court expressed sympathy for artists, noting that the law can be overly complex for them and that they often face difficulties in receiving their rightful compensation. The Court also noted that Sony Music had initially released the song on a commercial scale in 2014 but had assigned the song’s rights to Hardeep Singh Sidhu in 2018 through an exclusive and absolute assignment.

Sartaaj had assigned the rights to 12 songs sung during a concert at the Sydney Opera House to Saga Music. He was supposed to be paid ₹50 lakhs for the performed songs but had only received ₹25 lakhs so far. In July of the current year, Sartaaj terminated the agreement, claiming it was fraudulently executed. Sartaaj conceded during the hearing that he could not have executed the agreement with Saga Music while he had already assigned the underlying works to Sony in 2014.

The Court determined that no rights could have been assigned in the underlying works to Saga Music. Even if Sartaaj intended to exploit the public performance in the Sydney Opera House concert, he should have first obtained permission from Sony or Sidhu.

The Court, while inclined to protect Saga Music’s interests, balanced the interests of the defendants as well. After Sartaaj volunteered to deposit the amount with the Court within one week, the bench rejected the request for an interim injunction, with the deposits being without prejudice to the rights and contentions of the parties appearing before the court.