Sagar Shinde vs. Jio Studios Case: Patiala House Court Rules on Copyright & Film Titles | Apar Law Insights
- Kiratraj Sadana
- May 2, 2025
- 3 min read
Updated: May 14, 2025
Date of Order: 24th April 2025
Court: Patiala House Court, New Delhi
Judge: Hon’ble Ms. Vineeta Goyal
Case No.: CS (COMM.) 282/25
🔎 Case Summary
On 24th April 2025, the Patiala House Court dealt with a high-stakes copyright dispute involving Sagar Shinde, a Marathi content creator, and Jio Studios alongside other defendants. The Plaintiff sought to restrain the release of the Marathi film "Zapuk Zapuk", scheduled to premiere the very next day, alleging that the movie infringed his registered copyright in a sound recording.
According to Mr. Shinde, the phrase "Zapuk Zapuk" — meaning "extremely amazing for the creator" in Marathi — was his creation and had gained popularity when a contestant used it during a TV reality show episode. The Plaintiff alleged that the Defendants adopted this phrase as the title and promotional hook for their new film without authorization, violating his copyright.
⚖️ Key Arguments
Plaintiff’s Contentions:
The film’s title and promotional materials unlawfully used the phrase "Zapuk Zapuk."
This constituted copyright infringement of his registered sound recording.
The Defendants' use was deceptively similar, likely to cause public confusion.
An urgent injunction was necessary to prevent irreversible commercial harm.
Defendant No. 1 (Jio Studios) Response:
Copyright in a sound recording does not grant exclusive rights over the title of the work.
Titles, by themselves, are generally not protected under copyright law.
The Plaintiff delayed approaching the Court, only seeking relief one day before the movie’s release, despite having known about the alleged infringement months earlier.
Significant investments had already been made, including distribution rights and screen bookings.
Other Defendants (Producers & Platform Partners):
Echoed the concerns about the plaintiff’s delay.
Argued that such a last-minute injunction would cause disproportionate commercial harm.
🏛 The Court’s Decision
The Court declined to grant an interim injunction stopping the release of the film.
However, it acknowledged the Plaintiff’s registered copyright and the potential merits of his claim. To protect the Plaintiff’s financial interests pending a final decision, the Court ordered the Defendants to maintain detailed accounts of all revenues and profits from the release of "Zapuk Zapuk."
👁️ Practical Insights — What This Means for Creators & Businesses
Copyright vs. Titles : Having a copyright over a recording or phrase does not automatically give you rights over a title. Titles generally fall outside the scope of copyright protection.
Timing is Crucial : If you suspect infringement, act immediately. Delays can weaken your case and prevent Courts from granting urgent relief.
Balancing Rights & Commerce: Courts must balance the creator’s rights with the commercial realities and investments of businesses. Prior restraint — blocking speech or content before release — is only granted in exceptional cases.
Maintain Documentation : Content creators should register their works and keep records of first use to strengthen infringement claims.
Commercial Parties Beware : Producers and brands should conduct IP clearance checks before adopting phrases, slogans, or content that may have been created or popularized by others.
This case underscores the fine line between protecting creative rights and recognizing the commercial interests of businesses that invest significantly in content development. It is advisable for both creators and enterprises to:
Secure timely registrations for all intellectual property.
Monitor markets proactively for possible infringements.
Approach courts without undue delay when rights are infringed.
For businesses : implement rigorous IP due diligence before public releases.
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