Court holds applicant failed to establish clear enforceable copyright, dismisses plea to restrain worldwide release of Hindi version amid contested assignments and settlements
In a significant ruling concerning film remake rights, the Madras High Court on October 1, 2026, dismissed an application seeking interim protection against the release and exploitation of the Hindi remake of the Malayalam film "Drishyam 3." The application was filed by Rajkumar Theatres Pvt. Ltd., which claimed joint ownership of the remake rights in Hindi and sought to restrain M/s. Wide Angle Creations and others from releasing the Hindi version globally.
The dispute centers around copyright ownership and the right to remake the Malayalam film "Drishyam 3" in Hindi. The applicant, Rajkumar Theatres Pvt. Ltd., based its claim on a series of agreements dating back to 2013 and 2014, under which it initially acquired exclusive remake rights for the original "Drishyam" film and its sequels in Telugu, and a joint ownership arrangement with the first respondent for Hindi and North Indian language remake rights.
The applicant contended that it had funded the acquisition of the Hindi remake rights and was entitled to a 50% share. It further claimed that the respondents had infringed upon its copyright by producing and planning to release the Hindi remake of "Drishyam 3" without its consent.
However, the respondents opposed the application, arguing that the applicant had no subsisting exclusive rights over the Hindi remake of the third sequel due to subsequent assignments and settlement agreements. They contended that the applicant had assigned relevant Hindi and derivative rights to Viacom 18 in 2014 and that any rights claimed under earlier agreements were subject to and overridden by later transactions.
Justice K. Govindarajan Thilakavadi, presiding over the matter, observed that the applicant failed to place before the Court any clear and enforceable material establishing its exclusive or joint copyright in the Hindi remake rights of "Drishyam 3." The judge noted that the competing claims involved complicated contractual arrangements, including subsequent assignments and settlement documents, which required thorough adjudication.
Given the serious consequences that an interim injunction would have on the rights of the respondents and third parties, the Court emphasized the necessity for the applicant to demonstrate a prima facie case of infringement with clear evidence. The Court was not convinced that the applicant had met this threshold at the interlocutory stage and declined to grant the sweeping interim restraint sought.
The judgment underscores the importance of clear documentation and enforceable rights when seeking interim relief in intellectual property disputes, particularly in cases involving multiple assignments and derivative rights across different language versions of films.
Bottom Line:
Arbitration and Conciliation Act, 1996 Section 9 Interim protection sought in relation to alleged copyright in Hindi remake rights of film "Drishyam 3" - Applicant seeking to restrain worldwide release and exploitation of Hindi remake - Where applicant failed at interlocutory stage to place clear material establishing subsisting enforceable exclusive or joint copyright, and rights claimed were seriously disputed in view of subsequent assignment and settlement documents, sweeping interim injunction cannot be granted.
Statutory provision(s):
Arbitration and Conciliation Act, 1996 Section 9, Copyright Act, 1957 Section 62
Rajkumar Theatres Pvt. Ltd. v. M/s. Wide Angle Creations, (Madras) : Law Finder Doc Id # 2990652
