The case involves two commercial IP suits filed by Indian Performing Right Society Limited (IPRS) against Rajasthan Patrika Private Limited and Music Broadcast Limited. IPRS is a company incorporated in 1969 with the objective of protecting and enforcing the rights, interests, and privileges of authors, composers, and publishers of literary and musical works. The defendants in both suits are engaged in operating FM Radio Broadcast channels, including 'Radio Tadka' and 'Radio City FM.' Both defendants had entered into license agreements with IPRS for utilizing their repertoire of literary and musical works.

Issues Raised:

1. Whether the plaintiff - IPRS is entitled to receive royalty payments from the defendants for the communication of musical works to the public through their FM radio broadcast channels?
2. Whether the amendments brought about in the Copyright Act with effect from 21.06.2012 have any impact on the rights of the authors of original works when the sound recordings, wherein such original works have been utilized, are communicated to the public?

Rules And Applications:

• The Copyright Act, 1957 provides for the protection of literary, dramatic, musical and artistic works and cinematograph films and sound recordings.
   
• Section 14 of the Act provides for various exclusive rights to the owner of copyright in a work, including the right to communicate the work to the public.
   
• Section 33 provides for the registration of copyright societies, such as the plaintiff - IPRS, and authorizes them to carry on copyright business in literary and musical works.
• The Copyright (Amendment) Act, 2012 brought about significant changes in the Copyright Act.
   
• Section 18 of the Act was amended to provide that the author of the original literary or musical work, or the owner of any right in such work, shall have the right to receive royalties from the commercial exploitation of such work, including by way of communication to the public.
   
• Section 19 was amended to provide that no one shall make any alteration to a literary or musical work without the consent of the author or the owner of any right in such work.
   These amendments were brought about in order to ensure that the authors and creators of works receive fair remuneration for the commercial exploitation of their works.

Analysis:
In the present case, the plaintiff - IPRS is seeking royalty payments from the defendants for the communication of musical works to the public through their FM radio broadcast channels. The defendants had entered into license agreements with the plaintiff - IPRS for the utilization of the repertoire of literary and musical works of the plaintiff as a part of their FM radio broadcast. However, the defendants are now contending that the authors of the original works or the underlying literary and musical works embodied in sound recordings have no right to interfere with the rights of owners of such sound recordings to communicate the same to the public, including by broadcast through their radio stations.

The Supreme Court in the case of Indian Performing Rights Society (IPRS) Vs. Eastern Indian Motion Pictures Association and others, 1977 AIR 1443, had held that once the author of the original literary or musical work assigned the same to a producer of a cinematograph film, such author of original works could no longer claim any further right from such producer when the cinematograph film was communicated to the public. This position of law has been reiterated in subsequent judgements of the Supreme Court and judgements / orders of various High Courts, despite amendments brought about in the Copyright Act in the year 1994.

However, the Copyright (Amendment) Act, 2012 brought about significant changes in the Copyright Act, which may have an impact on the rights of authors of original works when the sound recordings, wherein such original works have been utilized, are communicated to the public. Section 18 of the Act was amended to provide that the author of the original literary or musical work, or the owner of any right in such work, shall have the right to receive royalties from the commercial exploitation of such work, including by way of communication to the public. Therefore, the plaintiff - IPRS may be entitled to receive royalty payments from the defendants for the communication of musical works to the public through their FM radio broadcast channels, despite the earlier judgements of the Supreme Court and various High Courts.

Conclusion
Based on the above analysis, it can be concluded that the plaintiff - IPRS may be entitled to receive royalty payments from music streaming platforms in India, as they are legally required to obtain a license from IPRS to use copyrighted music. However, the amount of royalty payments will depend on various factors such as the revenue generated by the platforms, the number of songs used, and the duration of usage.

It is important for IPRS to continue to actively monitor and enforce their rights in order to ensure that they receive fair compensation for the use of their members' copyrighted music. In addition, music streaming platforms should also ensure that they comply with all legal requirements and obtain the necessary licenses to avoid potential legal action from IPRS or other copyright holders.