Disclaimer: This has been reported after the availability of the order of the Court and not on media reports so as to give an accurate report to our readers.
Madras High Court: In an application seeking interim injunctions under Section 9(1)(d) of the Arbitration and Conciliation Act, 1996 (the Act), restraining the respondents from creating third-party rights or releasing the film ‘Akhanda 2’ until an arbitral award was paid, a single-judge bench of N. Anand Venkatesh, J., vacated the interim order of injunction and permitted the release the movie ‘Akhanda 2,’ as the parties agreed to settle Film distribution dispute and part payment is already done.
In the instant matter, the applicant-Eros International had earlier acquired rights and held a lien over several films produced by respondent-14 Reels Entertainment, on account of unpaid amounts under the Film Distribution Agreement dated 20-12-2013, Assignment Agreement dated 17-10-2015), Agreement-cum-Undertaking dated 17-10-2015, and the Arbitral Award dated 23-07-2019. Due to continued non-payment by respondent, the applicant sought to restrain exploitation of film ‘Akhanda 2’ pending satisfaction of the award.
The applicant filed application seeking interim injunctions restraining the respondents from creating third-party rights or releasing the film ‘Akhanda 2’ until an arbitral award amount of ₹27,70,97,298/- with 14% interest was paid.
These applications were dismissed vide order dated 30-10-2025. On appeal, the Division Bench, vide order dated 03-12-2025, set aside the dismissal and remitted the matter to the Single Judge for adjudication on merits while granting an interim injunction pending such hearing. The Bench directed that the interim relief “will continue till the main applications are taken up for final hearing.”
Upon remand, the parties informed the Court that they had arrived at a settlement vide Settlement Agreement dated 08-12-2025, facilitated by Mango Mass Media (P) Ltd.-respondent 3.
The Court noted that all parties agreed that the applications could be disposed of in terms of the Settlement Agreement, and that the agreement should form part of the final order. The Court observed that the Division Bench had directed that the interim injunction would continue “till the main applications are taken up for final hearing,” and opined that since the applicant had already received ₹5 Crores via RTGS, constituting the part settlement amount, the basis for continuation of the injunction no longer remained. The Court also noted that a cheque for ₹10 Crores had been handed over to the applicant’s representative in Court.
The Court held that all applications are disposed of in terms of the Settlement Agreement dated 08-12-2025, which was ordered to “form part of this order.” In light of the receipt of ₹5 Crores, the Court vacated the he interim order of injunction and permitted the respondent 2 to release the movie ‘Akhanda 2’.
[Eros International Media Ltd. v. 14 Reels Entertainment (P) Ltd., 2025 SCC OnLine Mad 12071, Decided on 10-12-2025]
*Judgment by Justice N. Anand Venkatesh
Advocates who appeared in this case:
Mr. Akash Srinanda V for Ms. Vaibhav R Venkatesh, Counsel for the Applicant
Mr. Keerthikiran Murali, Counsel for the Respondent No. 1
Mr. P. Giridharan, Counsel for the Respondent No. 2
Mr. C. Prasanna Venkatesh, Counsel for the Respondent No. 3
Buy Arbitration and Conciliation Act, 1996 HERE
