Key Copyright Law Developments in India During 2025: Court Rulings and AI Policy Advances

Copyright law in India governs the rights over original literary, artistic, musical, and other creative works. However, the application of these principles has become increasingly complex amid rapid technological advancements. Throughout 2025, courts and policymakers confronted critical questions involving music licensing, protection of classical compositions, personality rights in the age of AI, and the intersection of artificial intelligence with copyright law.

One of the year’s landmark rulings came from the Delhi High Court in Azure Hospitality v. Phonographic Performance Ltd., where the court held that only registered copyright societies—not individual copyright owners—may conduct licensing businesses in India. This decision challenged PPL’s longstanding practice of licensing music recordings without formal society registration. The court rejected PPL’s argument that valid copyright assignments conferred inherent licensing rights, emphasizing that Section 33(1) of the Copyright Act imposes mandatory restrictions on commercial licensing activities. This ruling fundamentally reshapes India’s music licensing landscape, mandating that entities engaged in commercial licensing either register as copyright societies or operate through such registered bodies.

In April 2025, India’s Department for Promotion of Industry and Internal Trade announced the formation of a committee to examine the intersection of artificial intelligence and copyright law. The committee’s mandate includes identifying legal and policy challenges, assessing whether the Copyright Act of 1957 adequately addresses emerging AI-related issues, and recommending potential legislative updates. Key topics under review include the copyrightability of AI-generated works, ownership of rights in such works, whether training AI models on copyrighted materials constitutes infringement, and the applicability of existing exceptions in AI contexts. The committee’s forthcoming recommendations are anticipated to be crucial for creators, technology companies, and legal practitioners.

The Delhi High Court also adjudicated a significant copyright dispute involving the film composition ‘Veera Raja Veera’ from Ponniyin Selvan 2. Ustad Faiyaz Wasifuddin Dagar claimed that the song substantially copied the melodic structure and rhythmic patterns of ‘Shiva Stuti,’ an original Dhrupad composition by the Junior Dagar Brothers. The court recognized ‘Shiva Stuti’ as a protectable original musical work and found prima facie evidence of infringement. It ordered that credits acknowledging the Dagar Brothers be displayed wherever the song is used and imposed a Rs. 2 crore security deposit. The judgment carefully distinguished between unprotectable traditional elements and the unique expression embodied in the Dagar Brothers’ specific arrangement.

Addressing emerging challenges posed by technology, the Delhi High Court granted an ex-parte interim injunction protecting actress Aishwarya Rai Bachchan from unauthorized use of her name, image, and likeness. The case involved violations through deepfake videos, counterfeit merchandise, and AI-generated impersonation content. Recognizing the misuse of her persona via advanced technological tools including artificial intelligence, the court directed platforms to remove infringing content within 72 hours and provide user details within seven days. It also issued John Doe injunctions against unknown defendants. This ruling stands as one of India’s early judicial pronouncements specifically tackling deepfakes and AI-generated impersonation.

In a copyright dispute concerning a biographical film script, the Karnataka High Court clarified a fundamental principle: ideas and historical facts are not protectable under copyright law—only their specific expression is. Rajiv Menon asserted exclusive rights over a script for a biopic on legendary singer M.S. Subbulakshmi, claiming it was derived from his book ‘MS – A Life in Music.’ The High Court reversed the trial court’s decision, finding no substantial similarity between the script and the book. Similarities were attributed to factual content already in the public domain. This judgment provides important guidance for filmmakers and authors working on biographical subjects, affirming that multiple works about the same historical figure can coexist if each reflects independent creative expression.

The Delhi High Court further ruled in favor of Al Hamd Tradenation in a dispute over music licensing fees for a small corporate event. Al Hamd sought to organize a 50-person gathering and challenged PPL’s quoted fee of Rs. 49,500, countering with Rs. 16,500 based on event size. The court held that offering a license on unreasonable or arbitrary terms constitutes a constructive refusal. It underscored the need to balance creator protections with public access to works, especially when licensing fees become prohibitively high.

In another Delhi High Court decision, a Division Bench ruled in favor of composer A.R. Rahman, rejecting claims by the Dagar Brothers that they authored the musical composition ‘Shiva Stuti.’ The court found insufficient evidence that the Junior Dagar Brothers were the work’s creators, noting they were credited solely as performers rather than composers. The ruling emphasized the critical distinction in copyright law between performance rights and compositional copyright, clarifying that performers do not automatically acquire authorship rights by virtue of performance.

Finally, the Delhi High Court issued a permanent injunction and awarded damages to fashion designer Gaurav Gupta in a trademark and design infringement case. The defendant had been manufacturing and selling counterfeit replicas through online channels, including YouTube and social media platforms. This ruling reinforces the judiciary’s commitment to protecting intellectual property rights against counterfeiting in the digital marketplace.

Collectively, these judicial pronouncements and policy initiatives in 2025 have significantly influenced India’s copyright landscape. They offer vital reference points for creators, businesses, and legal professionals navigating the evolving challenges of copyright law in an era marked by technological innovation and increasing digital content consumption.