Delhi High Court Rejects Former Cineyug Employee's Claim Over 'IPL Awards' Copyright, Moral Rights

The Delhi High Court on Friday dismissed a long-running copyright dispute over the “IPL Awards”, holding that Gaurav Garg, a former employee of Cineyug Films Pvt. Ltd., cannot claim authorship or moral rights over the event's concept and presentations. The court ruled that the copyright vested in the company, not in Garg.

A single-judge bench of Justice Tejas Karia delivered made the ruling while deciding a suit filed by Garg against filmmaker Aly Morani, Mohomed Morani, and Cineyug Films, which organised the IPL Awards.

Garg had claimed that he was the conceptualiser and author of the IPL Awards format and alleged that he was denied due credit when the event was eventually held and broadcast. He argued that, as a consultant associated with Cineyug between 2008 and 2009, he had developed the idea and prepared detailed presentations. This, according to him entitled him to authorship and moral rights under Section 57 of the Copyright Act, 1957.

Rejecting these claims, the court held that Garg failed to prove that he was the author of the literary work underlying the event.

“In the present case, the Plaintiff has not been able to establish that the Plaintiff is the author of the literary work embodying the presentation and written expression of the Event as held above in relation to Issue (i). Accordingly, the Plaintiff cannot claim special rights in the capacity of an author as provided under Section 57 of the Act.” the court said.

It added that, as a result, Garg could not claim special rights as an author under Section 57.

Cineyug and its promoters contested Garg's version, asserting that he was working as an employee at the relevant time and that any work created during his employment belonged to the company. They also pointed out that Garg had not produced the original written concept and had relied only on presentations prepared jointly by a larger team.

After examining the record, the court noted that Garg did not complete his cross-examination despite several opportunities over the years. As a result, many documents relied upon by him remained unproven. Email records, on the other hand, indicated that he functioned as an employee of Cineyug during the relevant period.

“The Plaintiff has only relied upon the Presentation and the 'Detailed Concept Note & Feasibility Study', which is not the exclusive work of the Plaintiff as admittedly, it was created by Cineyug Signature Team,” the court observed.

The court further held that under Section 17(c) of the Copyright Act, when a work is created in the course of employment, the employer is the first owner of the copyright unless there is an agreement to the contrary. Since no such agreement was shown in this case, the rights vested with Cineyug.

On moral rights, the court said that because Garg failed to establish authorship, he could not invoke Section 57. It added that, in any event, there was no allegation of distortion, mutilation, or modification of the work.

The suit was accordingly dismissed, with the court rejecting Garg's claims for injunction, damages, rendition of accounts, and recognition as the author of the IPL Awards concept.