RG Anand vs Delux Films
1978 AIR 1613
Case Summary
[Intellectual Property]
[Copyright]
Facts
R.G. Anand, a playwright, claimed that Delux Films infringed his copyright by producing a film titled New Delhi, which he alleged was based on his play Hum Hindustani. Anand had engaged in discussions with Delux Films about adapting his play for film but received no follow-up communication. After the film's release in 1956, Anand filed a suit claiming damages and an injunction against the film's exhibition.
Issues
The key issues were:
Whether Delux Films' production of New Delhi constituted copyright infringement of Anand's play Hum Hindustani.
What constitutes substantial similarity in terms of copyright protection between two works.
Relevant Legal Provisions
Copyright Act, 1911: Governing principles related to copyright infringement.
Copyright principles: The distinction between ideas (which are not protected) and their expression (which is protected).
Judgement
In a landmark decision, the Supreme Court of India ruled against R.G. Anand, affirming the lower courts' findings that no copyright infringement occurred. The Court emphasized the idea-expression dichotomy, stating that copyright law protects only the expression of ideas, not the ideas themselves. The judges found that while both Hum Hindustani and New Delhi shared a common theme of provincialism, this theme was not unique or original to Anand's play and thus could not be claimed as proprietary.
The Court meticulously analysed both works and concluded that there were substantial differences in narrative structure, character development, and overall treatment between the two. It noted that any similarities were trivial and related to common ideas that are not protected by copyright. The judges asserted that a reasonable person viewing both works would not perceive New Delhi as a copy of Hum Hindustani.
Furthermore, the Court reiterated that for a claim of infringement to succeed, there must be substantial and material reproduction of the original work's expression, which was not evident in this case. The judgement underscored that mere thematic similarities do not suffice for establishing copyright infringement and established critical legal principles regarding what constitutes substantial similarity in copyright cases. This ruling has since become a cornerstone in Indian copyright jurisprudence, guiding future cases on similar issues.
Nitya Desai
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