Bombay High Court: No Copyright in Film Titles, ‘Lootere’ Injunction Plea Dismissed

Shreya Gupta

On 18th August, 2025, the Bombay High Court rejected a plea for interim injunction filed by the producer of the 1993 Hindi film Lootere. Bench of Justice Sandeep Marne heard the matter. The producer, Sunil Darshan Saberwal, wanted to stop Disney+ Hotstar (now JioHotstar) from releasing a web series with the same title. He argued that he had exclusive rights over the name Lootere because he had registered it with the Western India Film Producers Association (WIFPA) in 2010 and also held copyright registration for the 1993 film.

However, Justice Sandeep Marne made it clear that registering a title with an association does not create any legal rights under the Copyright Act, 1957. The Court explained that a film or book title is not considered a “work” under the Act, and therefore, copyright cannot exist in just a title. The judge further noted that registrations with associations like WIFPA are only private arrangements that bind their members, and since Star India was not a member, it was not affected by such rules.

The Court also took into account the delay on the plaintiff’s part. Even though Saberwal knew about the web series as early as 2022, he only filed the case in March 2024, just before its release. By the time the matter reached court, the series had already been released and was streaming. In this situation, the Court felt that an injunction would serve no real purpose. Dismissing the plea, the Court reaffirmed the settled position that film titles, by themselves, are not protected under copyright law.

Case Title: Sunil S/o Darshan Saberwal v Star India Pvt. Ltd

Bench: Justice Sandeep Marne

Case Number: Interim Application No. 3347 OF 2024

Click here to access the order

Instagram: Click here

LinkedIn: Click here

For Collaboration and Business: info.desikaanoon@gmail.com