The Madras High Court's decision on Tuesday (November 19, 2024) has significant implications for the awarding of prestigious titles in the field of Carnatic music. The court cleared the way for the Music Academy to confer the 'Sangita Kalanidhi' award on Carnatic singer T.M. Krishna and also allowed The Hindu to present another mirror award with a cash prize of ₹1 lakh to him on January 1, 2025. However, there were certain conditions attached to these awards.

Justice G. Jayachandran's Orders

Justice G. Jayachandran ordered that the mirror award with the cash prize should not be named after M.S. Subbulakshmi as she had expressed her wish in a 1997 will that no such trust or memorial should be established in her name. The court's decision was based on a civil suit filed by V. Shrinivasan, who claimed to be Subbulakshmi's grandson and opposed the conferment of the mirror award on Mr. Krishna due to his critical remarks against her.The judge emphasized that Mr. Krishna's opinions about M.S. Subbulakshmi would not disqualify him from receiving the 'Sangita Kalanidhi' title. The suitability for the award was to be decided by the Music Academy's executive committee, not the plaintiff. He also stated that if The Hindu wanted to honor the Sangita Kalanidhi with a cash prize, it could not be restrained just because Mr. Krishna had made unpleasant remarks in the past.On the other hand, the judge accepted the plaintiff's contention regarding the contents of his grandmother's will. He ruled that it would be against Subbulakshmi's wish to name the mirror award after her. The court cannot neglect its responsibility to enforce the dead person's wishes and mandates.The judge further observed that the terms of the will should be understood from the testator's perspective. He emphasized that the wish and mandate of M.S. Subbulakshmi should prevail over any attempts to honor her in a way that goes against her wishes.

The Locus Standi and Restraints

The judge held that the plaintiff had the locus standi to file the suit and that the balance of convenience was in his favor. As a result, the Music Academy and The Hindu were restrained from giving away the cash prize with the title 'Sangita Kalanidhi M.S. Subbulakshmi Award' until the disposal of the civil suit. However, the judge clarified that this order would not prevent the Music Academy from conferring the 'Sangita Kalanidhi' title on T.M. Krishna or The Hindu from distributing the cash prize to him without using Subbulakshmi's name.

The History and Context of the Awards

For several decades, the Music Academy has been conferring the 'Sangita Kalanidhi' award, which includes a gold medal and a citation. In 2005, The Hindu instituted another award titled 'Sangita Kalanidhi M.S. Subbulakshmi Award' with a cash prize to be given to the same person selected for the 'Sangita Kalanidhi' each year. The Music Academy and The Hindu argued before the High Court that many awards named after M.S. Subbulakshmi had been established by various entities, but the plaintiff had selectively challenged only one such award.This complex legal battle highlights the importance of respecting the wishes of the departed and the role of the judiciary in ensuring that such wishes are upheld. It also showcases the significance of these prestigious awards in the world of Carnatic music and the impact they can have on the careers of the recipients.