IPRS and PPL India explained: who collects for your song, who collects for your recording, and what changed in 2025

If you release music in India, two acronyms keep coming up: IPRS and PPL. They are often mentioned together, they are not the same kind of body, and in 2025 a court ruling made the gap between them sharper. This guide sets out what each one stands for, where the law currently sits, and what an independent artist can actually do about it.

It is general information, not legal advice. It describes the position as the court records and statute below state it on 25 Oct 2026. We could not open the IPRS or PPL India websites while writing (both blocked automated access), so we do not quote their fees, forms or current membership terms. Check those directly before you sign anything.

Two copyrights, two collectors

Every released track carries two copyrights. One is in the song: the composition and the lyrics, owned by the composer, lyricist and any publisher. The other is in the sound recording (the master), usually owned by whoever paid for the recording, often a label. Our guide to performing rights organisations covers the song side worldwide; neighbouring rights explained covers the recording side in the UK and US.

In India the two sides map roughly like this:

• IPRS (the Indian Performing Right Society) represents composers, lyricists and music publishers, licensing the song.
• PPL India (Phonographic Performance Limited) licenses sound recordings that labels have assigned to it, for uses such as public performance in venues and broadcast.

So a song played over the speakers in a restaurant can, in principle, need two permissions: one for the underlying song and one for the recording.

Why "registered copyright society" matters

The Copyright Act, 1957 does not let just anyone run a licensing business. Section 33(1), as quoted in the Delhi High Court's 2025 judgment, says no person shall "carry on the business of issuing or granting licences in respect of any work in which copyright subsists" except under a registration granted under Section 33(3). The first proviso keeps an owner's right to license "his own works" individually.

The 2012 amendment added Section 33(3A): a registration lasts five years, and renewal depends on "collective control of the copyright society being shared with the authors of works". Every society registered before 2012 had to register again. Section 33(3) also says the government will not ordinarily register more than one society for the same class of works.

That framework is what made the 2025 PPL case matter.

The 2025 Azure ruling, in plain terms

In Azure Hospitality v. Phonographic Performance Limited, decided on 15 April 2025, a Delhi High Court division bench (Justices C. Hari Shankar and Ajay Digpaul) looked at a restaurant operator that PPL had sued for playing its recordings. The judgment says at paragraph 25.5:

• there is "no embargo on PPL licensing the sound recordings assigned to it", but to do so PPL "would have either to be a registered copyright society or a member of one";
• PPL "is admittedly not a registered copyright society, though it was one at an earlier point of time";
• the copyright society registration for sound recordings "presently, vests only with RMPL" (Recorded Music Performance Limited).

As an interim arrangement, the court told Azure to pay PPL at RMPL's tariff, as if PPL were an RMPL member, pending the main suit. LiveLaw's report summarises the same points.

It did not end there. According to SCC Online, the Supreme Court stayed the High Court's payment directions on 21 April 2025 and, on 19 June 2025, said that stay binds only PPL and Azure. The underlying suit was still pending when the High Court ruled. So the reasoning stands as a strong signal, not a final word.

Where songwriters fit: the 2012 royalty right

For composers and lyricists the bigger story is the 2012 amendment's provisos to Sections 18 and 19, which deal with the royalty rights of authors whose songs are used in films and sound recordings. Read the Copyright Act on India Code for the exact text.

In 2023, as SpicyIP reported, the Bombay High Court read those provisos as giving lyricists and composers a right to royalties when a recording of their work is communicated to the public, for example on radio. That order was interim. Our news piece on India's radio royalties follows the fight that came after.

What an independent artist should actually do

If you write songs (composer or lyricist): IPRS is the society for you. One Indian production school's guide describes the process as an online application with ID proof, PAN, photo and signature, a membership fee, a choice of category (composer, lyricist or publisher), then registering each work through a member portal. Treat that as a starting checklist, not the official rules. The steps that hold regardless:

1. Agree written splits with every co-writer before release. Our metadata and split sheets guide has a template.
2. Register each work as soon as it is released, with the same titles and credits your distributor uses.
3. Keep a simple sheet of works, dates, co-writers and registration numbers.

If you own your masters: you are the "first owner" of the sound recording copyright. Under Section 33(1)'s first proviso you can license your own recordings individually. Whether joining PPL India or RMPL makes sense depends on how much your recordings are actually played in venues and on broadcast. For most bedroom releases that number is small. Ask either body in writing what they would collect for a catalogue your size, and what they would charge.

Before you sign anything: check whether you are being asked to assign your copyright (transfer ownership, which is how labels move recordings to PPL) or to license it. An assignment is much harder to undo.

What we think

The 2025 ruling is usually read as a fight between PPL and the hospitality industry. We think the more useful point for artists is quieter: Indian law already assumes collective licensing runs through societies where authors share control (that is what Section 33(3A) says). The Azure bench applied that assumption to recordings. That should strengthen the hand of the people who make the music, not just whichever body holds the most label assignments.

In practice, that only helps if artists turn up. A society where authors "share control" is only as good as the authors who vote, read the distribution scheme and ask for the numbers. Register your works, keep your splits clean, and when a society sends an AGM notice, read it. The structure is the law's job; using it is yours.

For the registration side of Indian copyright itself, see our guide to registering music copyright in India.