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Delhi High Court declines immediate injunction in Dhurandhar 2 dispute

The Delhi High Court was hearing a suit seeking an ex parte ad-interim injunction over alleged infringement of rights linked to earlier works including 'Dhurandhar 2'.

The plaintiff sought to restrain the defendants from exploiting “Dhurandhar 2”, alleging that it infringed rights connected to the film “Tridev” and related intellectual property.The plaintiff sought to restrain the defendants from exploiting “Dhurandhar 2”, alleging that it infringed rights connected to the film “Tridev” and related intellectual property. (Image enhanced using AI, File image)

Dhurandhar news: The Delhi High Court has declined to grant an immediate interim injunction in a commercial dispute over the proposed OTT release of the film “Dhurandhar 2”, instead directing the defendants to maintain detailed accounts of revenues generated from the film’s exploitation.

Justice Tushar Rao Gedela was hearing a suit filed by Trimurti Films Private Limited against B62 Studios Private Limited and others including Super Cassettes Industries Private Limited seeking an ex parte ad-interim injunction over alleged infringement of rights linked to earlier works.

“Having regard to the fact that the statement has already been tendered on behalf of the defendant no.1/B62 Studios Private Limited, no further particular orders in respect of passing an interim injunction may be passed at this stage as on date,’ the court said on April 9.

While declining interim relief, the court directed the defendants to maintain records of all revenue arising from the exploitation of the film 'Dhurandhar 2' from March 19, when it was launched. The court directed the defendants to maintain records of all revenue arising from the exploitation of the film ‘Dhurandhar 2’ from March 19, when it was launched. (Image enhanced using AI)

Court orders maintenance of accounts

The plaintiff sought to restrain the defendants from exploiting “Dhurandhar 2”, alleging that it infringed rights connected to the film “Tridev” and related intellectual property.

While declining interim relief, the court directed the defendants to maintain records of all revenue arising from the exploitation of the film ‘Dhurandhar 2‘ from March 19, when it was launched.

The court further observed that these records may be called for at a later stage, including in a sealed cover, if required. This direction ensures that financial equities can be safeguarded pending final adjudication.

Observing that no urgent restraint was warranted at this stage, particularly in view of a statement by the primary defendant that no OTT release of ‘Dhurandhar 2’ was planned before mid-May 2026, the court opted for a balanced approach that preserves financial records pending further adjudication.

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Defendants’ statement weighs on court’s decision

A significant factor influencing the court’s decision was a statement by B62 Studios Private Limited.
Senior Advocate Ravi Prakash, appearing for the studio, informed the high court that the company had no plans to release the film on any OTT platform before mid-May 2026.

Taking note of this assurance, the court held that no interim injunction was required “at this stage as on date,” and refrained from passing any immediate restraining order.

Dispute over rights to ‘Tridev’ content

The hearing saw detailed arguments concerning historical rights linked to the film “Tridev”.

Senior Advocate Akhil Sibal, appearing for Super Cassettes Industries Private Limited, referred to a 1988 receipt of Rs 7,000 allegedly issued by Trimurti’s founder Gulshan Rai as a signing amount, as well as prior legal notices from 2016 regarding the use of Tridev songs in another film.

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He argued that these documents demonstrated that the plaintiff had suppressed material facts and had not approached the court with clean hands, disentitling it from discretionary relief regarding the film Dhurandhar 2.

Plaintiff rebuts allegations

Senior Advocate Swathi Sukumar, appearing for Trimurti Films, strongly refuted these allegations, disputing both the authenticity and interpretation of the documents relied upon by the defendants.

She submitted that appropriate instructions would be obtained regarding the notices and the 1988 receipt and that a detailed response would be placed on record if necessary.

Mediation ordered

Noting that both sides expressed willingness to explore a settlement, the court referred the dispute to the Delhi High Court Mediation and Conciliation Centre.

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The parties have been directed to appear before the mediation centre on April 22 with the court requesting the appointment of a senior mediator conversant with the matter, which is related to Dhurandhar 2.

Procedural directions, next hearing

The court issued summons in the suit and set timelines for pleadings, directing the defendants to file their replies within ten days and the plaintiff to file a rejoinder within three days.

The matter has been listed for further hearing on May 6 while also being placed before the joint registrar on July 13.

Background, legal context

The dispute highlights issues of copyright ownership and assignment in the context of legacy film content being reused in contemporary productions.

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The court also granted exemption from pre-institution mediation under Section 12A of the Commercial Courts Act, citing urgency and relying on the Supreme Court’s ruling in Yamini Manohar vs TKD Keerthi (2024).

Conclusion

With no immediate restraint imposed but strict directions to preserve financial records, the Delhi High Court has taken a cautious approach that allows commercial activity to continue while protecting the plaintiff’s potential claims.

The case is now likely to turn on the outcome of mediation and the court’s eventual determination of contested rights dating back decades.

Vineet Upadhyay is an Assistant Editor with The Indian Express, where he leads specialized coverage of the Indian judicial system. Expertise Specialized Legal Authority: Vineet has spent the better part of his career analyzing the intricacies of the law. His expertise lies in "demystifying" judgments from the Supreme Court of India, various High Courts, and District Courts. His reporting covers a vast spectrum of legal issues, including: Constitutional & Civil Rights: Reporting on landmark rulings regarding privacy, equality, and state accountability. Criminal Justice & Enforcement: Detailed coverage of high-profile cases involving the Enforcement Directorate (ED), NIA, and POCSO matters. Consumer Rights & Environmental Law: Authoritative pieces on medical negligence compensation, environmental protection (such as the "living person" status of rivers), and labor rights. Over a Decade of Professional Experience: Prior to joining The Indian Express, he served as a Principal Correspondent/Legal Reporter for The Times of India and held significant roles at The New Indian Express. His tenure has seen him report from critical legal hubs, including Delhi and Uttarakhand. ... Read More

 

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