### Brief Introductory Head Note Summary of Case
This case involves a dispute over the use of old sound recordings for a private event. The plaintiff, a company organizing the event, sought a court declaration that playing certain pre-1965 songs, which they believed were no longer protected by copyright, did not infringe on the defendant's rights. The defendant is a company that manages music copyrights and licenses. The plaintiff feared interference from the defendant unless they paid a license fee, leading them to file the suit. The court ultimately disposed of the case after the event occurred without issues, noting the defendant's assurance that they do not claim rights over such old recordings. This highlights how copyright terms expire after a certain period, placing works in the public domain where anyone can use them freely.
### Factual Background
The plaintiff, Bignet Solutions LLP, was planning a private event on October 12, 2025. They wanted to play 15 specific sound recordings, all from before 1965, during the event. The venue hosting the event required the plaintiff to get a no-objection certificate or license from the defendant, Novex Communication Pvt. Ltd., which handles music licensing. On October 1, 2025, the plaintiff emailed the defendant asking for a license quote and included the list of song names. The defendant responded with a fee quotation. However, the plaintiff later checked and realized that under the law, copyrights in these pre-1965 sound recordings had expired, meaning they were now free for public use without needing permission or payment. The plaintiff only planned to play these old versions, not any newer recreations. Worried that not getting the license might lead to disruption of their event, the plaintiff filed a lawsuit seeking confirmation from the court that no infringement would occur and an order stopping the defendant from demanding fees for these songs.
### Procedural Detail
The suit was filed in the Delhi High Court as a commercial civil suit under the label CS(COMM) 1094/2025, along with three interim applications for urgent relief. It came up for the first hearing on October 10, 2025. At that time, the court heard arguments from both sides. The defendant stated they do not enforce rights over public domain works, while the plaintiff promised to play only the 15 listed pre-1965 songs and to provide a certified recording of the event afterward, signed by the venue. Based on this, the court issued interim orders allowing the event to proceed without interference. After the event on October 12, 2025, the plaintiff submitted documents, including a recording, to show compliance. The matter was heard again on November 21, 2025, where both parties made further submissions. The plaintiff argued the defendant should have clarified no fee was needed, while the defendant pointed out the email lacked release dates and complained about the short recording submitted. Ultimately, the court disposed of the suit and all applications on that date, without proceeding to a full trial.
### Core Dispute
The main issue was whether the plaintiff needed to pay a license fee to the defendant for playing 15 specific pre-1965 sound recordings at a private event. The plaintiff claimed these recordings were in the public domain because their copyright had expired under Section 27 of the Copyright Act, 1957, which sets a time limit on copyright protection. They argued that demanding fees for such works was wrongful. The defendant countered that they never claimed rights over these particular old recordings and that the suit was unnecessary, as they only license works they own or manage. A side issue was whether the plaintiff's email clearly specified the pre-1965 nature of the songs, and whether newer versions of some songs (like recreations in recent movies) could confuse matters. The plaintiff also sought damages, but the court found no basis for that. Overall, the dispute centered on clarifying rights over expired copyrights and preventing potential event disruption.
### Detailed Reasoning and Discussion by Court Including on Judgement with Complete Citation Referred and Discussed for Reasoning
The court began by outlining the plaintiff's suit, which sought a declaration that using the listed pre-1965 sound recordings did not infringe copyrights and an injunction against the defendant demanding fees. It noted the plaintiff's fear of interference at the event. Referring to Section 27 of the Copyright Act, 1957, the court accepted that copyrights in these recordings had expired, making them public domain and free for use without licenses. The court discussed the initial hearing on October 10, 2025, where it recorded statements: the defendant assured they do not enforce rights over non-owned or public domain works, and the plaintiff undertook to limit playback to the 15 songs and provide post-event proof. This led to interim orders allowing the event.
In the final hearing on November 21, 2025, the court examined the plaintiff's compliance evidence, including the event recording. Though the defendant criticized it as too short (about 25 minutes for a three-hour event) and unsigned by the venue, the court accepted it as sufficient, finding no contrary evidence that other songs were played. The court highlighted the plaintiff's email of October 1, 2025, which listed song names but not release dates, noting the defendant's point that some songs have modern recreations where they hold copyrights. However, the court emphasized the defendant's repeated statements—on October 10, 2025, and November 21, 2025—that they claim no rights over pre-1965 recordings and expect no licenses for them.
The court then analyzed the cause of action from paragraph 26 of the plaint: it arose on October 1, 2025, from seeking a no-objection certificate, and intensified on October 3, 2025, with the fee demand. Since the event occurred without interference and the defendant disclaimed rights, the court reasoned the core grievance was resolved. It found no merit in damages, as the plaint lacked supporting pleadings. The court clarified it expressed no opinion on allegations of misrepresentation, interference, or unjust enrichment by the defendant.
Notably, the judgement did not refer to or discuss any other case citations or precedents, relying instead on the facts, parties' statements, and direct application of Section 27 of the Copyright Act, 1957. This section provides that copyright in sound recordings lasts for 60 years from publication, after which it enters the public domain. The court used this to affirm that pre-1965 works are free for use. It declined the plaintiff's request for court fee refund, noting they skipped pre-institution mediation—a statutory step under the Commercial Courts Act to encourage settlements before suits—and instead used court processes for urgent relief.
### Decision
The court disposed of the suit and all pending applications, finding the cause of action satisfied. It accepted the plaintiff's compliance with the October 10, 2025, order and recorded the defendant's statement disclaiming rights over pre-1965 sound recordings. No damages were awarded, and the refund of court fees was denied. The court clarified it made no findings on broader allegations against the defendant.
### Concluding Note
This case underscores the importance of copyright expiration under Section 27 of the Copyright Act, 1957, ensuring old works become freely available to the public. It shows how courts can resolve disputes quickly when parties clarify positions, avoiding full trials. For event organizers, it highlights checking copyright status before licensing and communicating details clearly. For rights holders, it reminds them to avoid demanding fees for public domain works. Overall, it promotes fair use of cultural materials while encouraging amicable resolutions over litigation.
Case Title: Bignet Solutions LLP Vs. Novex Communication Pvt. Ltd.
Order Date: November 21, 2025
Case Number: CS(COMM) 1094/2025
Neutral Citation: 2025:DHC:1094
Name of Court: High Court of Delhi at New Delhi
Name of Hon'ble Judge: Hon'ble Ms. Justice Manmeet Pritam Singh Arora
Disclaimer: The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
Here are 5 suitable titles for this legal analytical article to be published as a legal research paper in a legal journal:
1. Expiry of Copyright in Sound Recordings: Analyzing Public Domain Usage in Bignet Solutions LLP v. Novex Communication Pvt. Ltd.
2. Navigating License Demands for Pre-1965 Works: Lessons from the Delhi High Court's Disposal in a Music Copyright Dispute
3. Public Domain and Event Licensing: A Case Study on Section 27 of the Copyright Act, 1957
4. Resolving Apprehended Infringement: Judicial Approach to Expired Copyrights in Private Events
5. Clarifying Rights Over Vintage Sound Recordings: Insights from a Swiftly Disposed Commercial Suit
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**Delhi High Court: No License Needed for Pre-1965 Sound Recordings in Public Domain – Suit Disposed of**
In a significant ruling clarifying the scope of copyright protection for vintage music, the Delhi High Court in the case of **Bignet Solutions LLP v. Novex Communication Pvt. Ltd., CS(COMM) 1094/2025**, decided on **21st November 2025** by **Hon’ble Ms. Justice Manmeet Pritam Singh Arora**, has held that sound recordings published before 1965 fall in the public domain under Section 27 of the Copyright Act, 1957, and no license or permission is required from any entity, including music licensing companies, to play such recordings.
The plaintiff had approached the court apprehending interference in a private event scheduled for 12th October 2025 after the venue insisted on a No-Objection Certificate (NOC) from Novex Communication Pvt. Ltd., a well-known music licensing company. When the plaintiff sought a license quotation for 15 specific pre-1965 songs, Novex quoted a fee, which prompted the plaintiff to file the suit claiming that the copyright in those recordings had long expired and the demand was unlawful.
On the very first hearing on 10th October 2025, the court recorded the statement of Novex that it does not claim or enforce any rights over sound recordings published before 1965 and does not require any license for such works. Based on mutual undertakings, the court permitted the event to proceed peacefully. After the event concluded without any disruption, the plaintiff submitted proof that only the 15 listed pre-1965 songs were played.
During the final hearing on 21st November 2025, senior counsel for Novex reiterated that these particular recordings never formed part of their repertoire and that they never intended to demand any fee for public-domain works. The court accepted the defendant’s categorical stand, noted that the event had been held smoothly, and held that the cause of action stood fully satisfied. Accordingly, the suit and all pending applications were disposed of. The court, however, declined the plaintiff’s prayer for damages and refund of court fees, observing that the plaintiff had bypassed the mandatory pre-institution mediation mechanism and directly invoked urgent court process.
The order serves as an important reminder that once 60 years have passed from the year of publication of a sound recording, it enters the public domain and can be freely used by anyone without payment or permission.
**Disclaimer:** This is for general information only and should not be construed as legal advice as it may contain human errors in perception and presentation: Advocate Ajay Amitabh Suman, IP Adjutor (Patent & Trademark Attorney), High Court of Delhi
