Copyright explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Part 4 of the Sound Recordings Manual lists thirteen issues seen during daily examination of applications, with the answer to each. Several repeat the film Manual's issues; the ones special to audio are the filing of a recording as a musical work, instrumental tracks and the music director's NOC. The rule behind most is rule 70, explained in our post on rule 70.
Status. The Manual was published by the Copyright Office in 2018 after public comments on a draft. It is the Copyright Office's guidance and does not have the force of law; the Copyright Act, 1957 and the Copyright Rules, 2013 as now in force prevail. The Office may revise its practice, so check the current position on copyright.gov.in.
A letter is expected where an album is filed on one application and one fee, where the consideration amount is blacked out, where the title does not match, where agreements are plain photocopies, and where a sound recording is filed as a musical work. A letter should not issue for a missing Statement of Further Particulars, an instrumental track with "NIL" language, or NOCs from people named only in Columns 11 and 12. Our objection reply service helps with a letter.
The thirteen issues in a table
| Issue | What the Office does | What to do |
|---|---|---|
| 1. Several tracks on one CD or drive | With a separate fee and application for each track, a shared medium is acceptable and no letter should issue. With one fee and one application for all, only one track can be registered, and the letter asks for a fresh copy of the chosen track | One application and fee per track |
| 2. Statement of Further Particulars | Not applicable to sound recordings; no letter for a missing, blank or incomplete one | Leave it out |
| 3. Consideration blacked out | Not acceptable; section 19(3) needs the amount shown | Show the amount |
| 4. Applicant is the sole creator | Affidavit that the applicant is the sole creator and no one else holds rights; original or notarised | File the affidavit |
| 5. Title mismatch | Title in Column 5 must match the title on the CD cover, the CD or within the recording; none at all, or a quite different one, is a discrepancy | Copy the title as it appears |
| 6. Photocopies of agreements | Originals or notarised copies; where several works share identical terms, original notarised copies of the same agreement are acceptable | File originals or notarised copies |
| 7. Sound recording filed as a musical work | A discrepancy arises, because a musical work means only graphical notation under section 2(p) and not words or actions performed with it | Choose the sound recording category |
| 8. Person's photograph on the CD or cover | No NOC if that person holds no rights, as the claim is for the audio-visual content | No NOC for the picture alone |
| 9. Language of an instrumental recording | Any language stated may refer to the lyrics meant to be sung; if purely instrumental, "NIL" is acceptable with no letter | Put the lyric language, or "NIL" |
| 10. Column 12 | Optional; others authorised to assign or license, apart from those in Column 11 | Fill if relevant |
| 11. NOCs from Column 11 and 12 persons | Not needed; section 14 gives the owner the right to authorise | Do not attach |
| 12. Music director working with a crew | The music director or directing company may sign the NOC or agreement for the artistes working for them, because they hold their own employment agreements | One NOC from the director or company |
| 13. Song titles | Names and titles are not subject to copyright protection | Do not file a title alone |
Notes on the audio-specific points
Albums. The disc is only a carrier; each track that is its own recording needs its own application, as rule 70(2) requires one work per application. Only one track can be registered against one fee and one diary number. See our article on the film Manual's issues, which has the same pattern.
Category. The musical work Manual defines a musical work as the composition in notation; our article on the musical works Manual explains why a recording belongs elsewhere. If your track is a cover, see our post on statutory licence for cover versions for the licence side.
Language. Column 6 asks for language. For a sung track, list the language of the words. For an instrumental track with no words, "NIL" is accepted.
Music directors. In a film or album session the music director often engages guitarists, violinists and drummers under their own agreements. The Manual lets the director or directing company sign on behalf of the artistes, so you do not need a separate NOC from each player.
How to answer a letter
- Identify which of the thirteen points the letter raises.
- If it is one of the points where the Manual says no letter should go (items 1(i), 2, 8, 9, 11), answer in one paragraph and refer to the Manual's own position.
- For the others, file the fix: a fresh single-track copy, the unmasked agreement, an original or notarised affidavit, or the corrected title.
- Keep documents original or notarised, as the Manual requires.
Remember that the Manual is guidance; the Act and the Rules as now in force prevail.
A worked example
Sana Qureshi, a musician, files one application and one fee for an EP of five tracks on a flash drive, with the agreement with her producer's company showing the consideration blacked out, and shows the language of the instrumental track as "NIL". The examiner's letter says only one track can be registered under that fee and asks which, and says the blacked-out agreement is not acceptable. The language entry draws no letter, since "NIL" is acceptable for a track with no words. Sana files four more applications with fees, one per track, and submits the unmasked agreement.
Need help with a music letter?
If your album or track application has drawn a letter, we can match it to the Manual's issues, prepare the corrected papers and write the reply through our copyright objection reply service.
Key takeaways
- One application and one fee per track.
- Show the consideration amount in agreements; file originals or notarised copies.
- Do not file a sound recording as a musical work.
- Instrumental tracks may show "NIL" for language.
- A music director can sign for the artistes in the crew; titles are not registrable.
Read next
- The five Copyright Office manuals and how an application is examined
- Cinematograph Films Manual: commonly observed issues
- Sound Recordings Manual: definition, publication, NOCs and agreements
- Musical Works Manual: author, adaptation and the sound recording line
Disclaimer: Based on the Practice and Procedure Manuals published by the Copyright Office in 2018 for literary, artistic, musical, cinematograph film and sound recording works, as consulted on 4 October 2026. The manuals are guidance and do not have the force of law; the Copyright Act, 1957 and the Copyright Rules, 2013 as now in force prevail, and current fees, forms and practice should be checked on copyright.gov.in. This article is general information, not legal advice; check the official text before acting.