The Bombay High Court has delivered a significant ruling concerning the intellectual property landscape of the Indian film industry, refusing to grant an interim injunction that would have halted the production and promotion of the upcoming movie Queen Full Power . Presided over by Justice Sandeep V. Marne, the court’s decision allows co-producers Jiostar India Pvt. Ltd. and Trigger Happy Entertainment to continue their work on the project, which features Kangana Ranaut and is directed by Vikas Bahl. The legal challenge, initiated by Phantom Studios India Pvt. Ltd., centered on assertions of ownership over the intellectual property of the 2014 hit film Queen and allegations that the new project constitutes an unauthorized derivative work.

The immediate consequence of the court’s order is that filming and promotional activities for Queen Full Power may proceed without judicial interference, bringing relief to the production teams who had faced uncertainty regarding the project’s future. Phantom Studios, which sought a comprehensive restraint on the use of the title and the development of any sequel or derivative content, argued that its co-production agreement—novated in 2022—mandated that no sequel or adaptation could proceed without mutual consent. Despite this claim, the court found that the plaintiff failed to establish a sufficient case to warrant the extraordinary measure of an interim injunction, noting that the balance of convenience heavily favored the current producers, especially given that principal photography is already complete.

Producers Move Forward Despite Ongoing Legal Challenges

The litigation highlights the growing complexity of franchise management in modern cinema. Phantom Studios asserted that it maintains a 50 percent ownership stake in the intellectual property rights associated with the 2014 film Queen . Initially, the studio targeted Jiostar India Pvt. Ltd. under the premise that it was the successor to Viacom 18, the original co-producer. Following procedural developments where the court identified that the relevant film rights had transitioned to Digital 18 Media Pvt. Ltd., the plaintiff expanded its legal focus. Phantom Studios maintained that the upcoming film was designed to exploit the goodwill of the original, labeling it a "spiritual sequel" meant to benefit from the established brand identity of the 2014 production.

During the proceedings, the defense presented a sharply contrasting view. Senior advocates representing the producers argued that Queen Full Power is an entirely original kidnapping thriller set in Mumbai, sharing no narrative DNA with the 2014 story of a young woman's solo honeymoon in Europe. Justice Marne, having reviewed a synopsis of the new film, observed that there was "no material on record to draw a prima facie conclusion that the proposed film borrows the essential elements or structural fabric of the film Queen ." By comparing the thematic structure of both works, the court determined that the structural elements of the story were distinct enough to defeat claims of it being a derivative work requiring contractual consent.

Court Dismisses Claims of Derivative Intellectual Property Violations

A core component of the plaintiff's argument rested on the belief that the title Queen had acquired "secondary meaning" in the minds of the public, effectively becoming a proprietary brand synonymous with the 2014 film. Phantom Studios relied on precedents suggesting that long-term box office success could elevate a film title to a protected status. However, Justice Marne rejected this interpretation of the current legal landscape. The court observed that the "sales figures" metric, often cited in older rulings, is no longer the sole determinant for establishing secondary meaning.

"There is conceptual difference between a successful film at the box office and the film needs to be a cult classic, the one which has developed loyal and passionate fan base over the time and has left a legacy," the court noted. Furthermore, the bench emphasized that Queen is a common, laudatory word that cannot be monopolized by any single entity. The court pointed out that numerous other films and digital content titles utilize the word, and that Phantom Studios had not previously objected to works such as Manikarnika: The Queen of Jhansi . The court reasoned that if the plaintiff’s restrictive interpretation were accepted, it would create an impossible hurdle for future filmmakers, effectively barring the use of common dictionary terms in titles.

Balancing Commercial Rights and Cinematic Artistic Expression

The ruling also touched upon the limits of actor recognition and thematic ownership. Phantom Studios had suggested that the combination of the lead actress, the specific theme of empowerment, and the Queen title created a protectable unit of interest. The court explicitly refuted this, holding that an actor’s professional identity and personal popularity remain their own and cannot be commandeered by a production studio. Justice Marne held that "Phantom cannot claim any proprietorship or monopoly in the alleged theme of discovery of power and confidence by a woman."

The legal battle over the ₹253.55 crore in damages remains unresolved, as the court left open the question of whether Jiostar India is a "veritable party" to the 2012 co-production agreement for trial determination. However, the immediate rejection of the injunction application signifies a major hurdle for the plaintiff’s attempts to freeze the project. By focusing on the lack of a " prima facie case of passing off or breach of contract ," the court has prioritized the right of the producers to continue their artistic endeavors, provided they remain within the bounds of the specific stories they have pitched.

The litigation, while currently favoring the defendants regarding the release of the film, will move into the next phase of discovery and full trial proceedings. For now, the stakeholders involved in Queen Full Power have successfully navigated the first major judicial challenge, allowing production schedules to remain intact. The court’s refusal to grant the injunction ensures that the film continues its journey toward potential release, serving as a reminder of the high threshold required to restrain creative works based on assertions of derivative property or goodwill appropriation in the absence of explicit contractual infringement.