The Bombay High Court has granted urgent interim relief to Phonographic Performance Limited (PPL) in a copyright infringement dispute involving the public performance of sound recordings during sports events.
Justice Sharmila U. Deshmukh passed an ad-interim order restraining Absolute Legends Sports Private Limited and others from playing copyrighted sound recordings without obtaining a licence from the plaintiff. The court noted that the defendants were already aware of the licensing requirement but had allegedly failed to obtain permission for upcoming matches.
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Background of the Case
The dispute arose after Phonographic Performance Limited, a copyright society that manages public performance rights of sound recordings, approached the court alleging infringement of its copyrighted works.
According to the plaintiff, the defendants organise sporting events and matches where music is played for audiences. PPL argued that any public performance or communication of its copyrighted sound recordings requires a licence from the organisation.
During the hearing, counsel for the plaintiff told the court that the respondents had previously obtained licences whenever matches were organised, demonstrating that they were aware of the requirement.
The plaintiff also relied on an undertaking dated December 23, 2023, given by the operations manager of the first respondent. In that undertaking, the company had acknowledged that whenever copyrighted sound recordings belonging to the plaintiff were used at events or premises under its control, it would obtain the required licence.
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Despite this assurance, the plaintiff alleged that the respondents had not obtained a licence for the upcoming matches scheduled in 2026.
Before approaching the court, PPL issued a legal notice on February 4, 2025, asking the respondents to obtain the necessary licence.
However, according to the plaintiff, no reply was received.
When the matter came up before the court, the plaintiff informed the bench that the respondents had been served notice of the hearing through email and WhatsApp. Despite service, no one appeared on behalf of the respondents during the hearing.
The plaintiff also placed on record the fixture schedule for upcoming matches, showing that games were planned on an almost daily basis. This, the plaintiff argued, raised a real apprehension that copyrighted songs would be played without permission during the events.
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After considering the submissions, the court noted that the defendants’ past conduct suggested they were well aware that a licence was necessary before using the plaintiff’s sound recordings.
The court observed that the earlier licences obtained by the defendants indicated knowledge of the plaintiff’s rights over the sound recordings.
“The procurement of licence in the past would indicate the knowledge of the respondents that it is necessary to obtain a licence from the plaintiff,” the court noted while examining the material placed on record.
Justice Deshmukh also referred to the undertaking of December 2023, which acknowledged the plaintiff’s rights and promised compliance whenever the recordings were used at events or premises controlled by the respondents.
The court further observed that the fixture list of upcoming matches showed a busy schedule, making the apprehension of potential copyright infringement reasonable.
The bench described the case as a “quia timet action”, meaning a legal action filed to prevent a possible future infringement where there is a credible threat that rights may be violated.
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In view of the circumstances, the Bombay High Court granted ad-interim relief in favour of the plaintiff.
The court restrained the respondents from publicly performing or communicating the plaintiff’s copyrighted sound recordings, or allowing their premises to be used for such purposes, without obtaining the required licence.
The matter has been listed for further hearing on April 8, 2026, and the interim protection granted by the court will continue until the next date of hearing.
Case Title: Phonographic Performance Limited v. Absolute Legends Sports Private Limited & Ors.
Case No.: Interim Application (L) No. 27758 of 2025 in Commercial IP Suit (L) No. 27133 of 2025
Decision Date: 12 March 2026
