What’s there in a Absorb registration? – An Indian Perspective
“Ques: Is it all-important to annals a assignment to affirmation copyright?
Ans: No. Accretion of absorb is automated and it does not crave any formality. Absorb comes into actuality as anon as a assignment is created and no academism is appropriate to be completed for accepting copyright. However, affidavit of allotment of absorb and the entries fabricated therein serve as prima facie affirmation in a cloister of law with advertence to altercation apropos to buying of copyright.”
The aloft catechism and the acknowledgment thereto, which anatomy allotment of the “Frequently Asked Questions” area of the (Indian) Absorb Office’s website www.copyright.gov.in, accomplish it bright in no ambiguous acceding that the allotment of absorb in India is alternative and there is no call to annals a copyrightable assignment to affirmation rights therein.
Coming from the anatomy accustomed beneath the (Indian) Absorb Act, 1957 (the Act) which is entrusted, inter alia, with the assignment of processing and registering absorb applications in India, this acknowledgment would appear to be a foregone conclusion.
However, the angle bidding by the Indian courts on this point accept not been as simple as the said answer. Over the years, the catechism whether absorb allotment is alternative or binding in India has presented itself to assorted Courts. While best of the Aerial Courts in India accept captivated that the allotment of absorb is alternative and not mandatory, there accept been a few cases area assertive Aerial Courts accept captivated otherwise.
Apart from presenting a birds eye appearance of the absitively cases on this point, this commodity additionally examines this affair from the angle point of the accordant approved accoutrement beneath the Act, the aldermanic absorbed on this actual point and additionally India’s obligations beneath all-embracing conventions, namely, the Berne Convention and the TRIPS Agreement, in this regard.
Relevant Accoutrement beneath the Act
“13. Works in which absorb subsists.
“17. Aboriginal buyer of copyright.
Subject to the accoutrement of this Act, the columnist of a assignment shall be the aboriginal buyer of the absorb therein.
“44. Annals of Copyrights.
There shall be kept at the Absorb Office a annals in the assigned anatomy to be alleged the Annals of Copyrights in which may be entered the names or titles of works and the names and addresses of authors, publishers and owners of absorb and such added particulars as may be prescribed”
“45. Entries in annals of Copyright
“48. Annals of Copyrights to be prima facie affirmation of particulars entered therein
The Annals of Copyrights shall be prima facie affirmation of the particulars entered therein and abstracts purporting to be copies of any entries therein, or extracts appropriately certified by the Registrar of Copyrights and closed with the allowance of the Absorb Office shall be acceptable in affirmation in all courts afterwards added affidavit or assembly of the original.”
None of the aloft accoutrement advance that allotment of absorb is binding in India. Neither Area 13(1), which deals with the affluence of absorb nor Area 17, which deals with the buying of absorb lists allotment as a pre-condition for claiming absorb in a copyrightable work. Further, the use of the announcement “may” in Sections 44 and 45 makes it abundantly bright that allotment of the particulars pertaining to a copyrighted assignment is optional. Lastly, in acceding of Area 48, the Annals of Absorb alone serves as a prima facie affirmation of the particulars entered therein and annihilation more.
Judicial Precedents – The adventure till date
In Mishra Bandhu Karyalaya and Ors. v. Shivratanlal Koshal, the Division Bench of the Madhya Pradesh Aerial Court, while referring, inter alia, to Area 45 of the Act empiric that allotment of a assignment appears to be a activity antecedent for accepting any absorb therein. While accomplishing so, the Cloister referred to the Indian Absorb Act, 1914 (which was accordant for the purposes of acknowledgment of the altercation afore the Court) and remarked that clashing the said Act, area there was no accouterment for any allotment of copyright, the accustomed Act does accommodate for the same. The Court, afresh went on to achieve that in the absence of a registration, an columnist of an aboriginal assignment can accept no rights or remedies, be it civilian or criminal, beneath the Act.
Expressing its altercation with the observations fabricated in Mishra Bandhu Karyalaya (supra) and terming them as animadversion dicta, the Madras Aerial Cloister in A. Sundarasan v. A.C. Thirulokchandar and Ors. empiric that the allotment of absorb is not compulsatory beneath the Act and non-registration does not disentitle a plaintiff affair to sue for contravention of his/her copyright. Apropos to Area 44 of the Act, the Cloister empiric that the adverse amid the chat “shall” in the beforehand allotment of the said area and the chat “may” in the afterwards allotment thereof makes it credible that although the aliment of the Absorb Annals is compulsory, the access therein of the names or titles of works and the names and addresses of authors, publishers and owners of absorb is larboard to the advantage of the buyer of the copyright. The Cloister afresh additionally referred to and relied on the use of the announcement “may” in Area 45 of the Act in abutment of its observation. The Cloister additionally went on to accredit to Area 48 of the Act and commented that if the Assembly had advised that allotment shall be compulsory, one would apprehend the accent of Area 48 to be radically altered from what it is now and it care to accept said that, afterwards registration, no accurate absorb could be claimed or enforced.
To agnate aftereffect is the accommodation of the Calcutta Aerial Cloister in Satsang and Anr. vs. Kiron Chandra Mukhopadhyay and Ors. wherein the observations fabricated in Mishra Bandhu Karyalaya (supra) were termed as animadversion dicta and it was empiric that there is annihilation in Area 45 or any added Area of the Act to advance that allotment of absorb is compulsatory and that the columnist can accept no appropriate or antidote in absence thereof. Similarly, in Kumari Kanaka vs. Sundararajan, a Division Bench of the Kerala Aerial Cloister captivated that allotment of the assignment beneath the Act is neither compulsatory nor a activity antecedent to advance a clothing for amercement for contravention of copyright.
The adjustment anesthetized in A. Sundarasan (supra) was challenged in address afore the Division Bench of the madras Aerial Cloister in Manojah Cine Productions v. A. Sundaresan and Anr. Dismissing the address and acknowledging the adjustment anesthetized in A. Sundarasan (supra), the Division Bench of the Madras Aerial Cloister empiric that there is hardly an adumbration in any of the accoutrement of the Act to advance that allotment is a activity antecedent to the affluence of absorb or accretion of buying thereof. While accomplishing so, the Division Bench additionally placed assurance on and bidding its acceding with the accommodation of Calcutta Aerial Cloister in Satsang (supra).
In Deepak Printery v. The Forward Stationery Mart and Ors., the Gujarat Aerial Cloister empiric that neither Area 13, nor Area 45 of the Act enjoins that a absorb charge be compulsorily registered. While celebratory so, the Cloister agreed with the appearance taken by the Calcutta Aerial Cloister in Satsang (supra) and bidding its altercation with the appearance taken by the Madhya Pradesh Aerial Cloister in Mishra Bandhu Karyalaya (supra).
This catechism afresh came up for appliance afore the Patna Aerial Cloister in Radha Kishna Sinha and Anr. vs. The Accompaniment of Bihar and Anr., admitting in the ambience of abolishment of the bent affairs accomplished beneath Area 63 of the Act in the absence of any absorb allotment in favour of the complainant. Apropos to Area 45 of the Act, the cloister empiric that it is alone an enabling accouterment and it does not go any added to authorization absorb registration. Cogent its acceding with the observations of the Calcutta Aerial Cloister and the Madras Aerial Cloister in Satsang (supra) and Manojah Cine Productions (supra) respectively, the Patna Aerial Cloister assured that allotment of absorb beneath the Act is not compulsory, nor it is sine qua non or a activity antecedent to the affluence of absorb or accretion of buying thereof or abatement for breach of copyright. Accordingly, the Cloister captivated that there was annihilation amiss in the Chief Administrative Magistrate demography cognizance of an answerability beneath Area 3 of the Act in the absence of allotment of absorb in favour of the complainant.
It was now the about-face of Allahabad Aerial Cloister to adjudge on this affair in Nav Sahitya Prakash and Ors. v. Anand Kumar and Ors. Apropos to Area 44 of the Act, the Cloister empiric that its purpose was not to accomplish allotment compulsatory or binding for the purpose of administration of absorb and if the assembly advised to accomplish the affirmation of allotment mandatory, the accent of Area 44 would accept been different. The Cloister additionally took agenda of the use of chat “may” in Area 45 and empiric that in accustomed acceptance “may” is acquiescent and is not about captivated to be binding unless the ambience requires to the contrary. The Cloister additionally empiric that in free the acceptation of any word, the aboriginal catechism to ask consistently is what is the accustomed and accustomed acceptation of the chat and it is alone back that acceptation leads to some added aftereffect which cannot analytic be accurate to accept been the ambition of the assembly that it is able to attending for some added accessible acceptation of the word. The Cloister afresh remarked that in the burning case, the ambience does not crave a acceptation altered than the ordinary. Cogent its altercation with the observations fabricated in Mishra Bandhu Karyalaya (supra) and accordant with the observations of the Madras Aerial Cloister and the Calcutta Aerial Cloister in A. Sundarasan (supra) and Satsang (supra) respectively, the Allahabad Aerial Cloister captivated that there is no accouterment in the Act depriving an columnist of the rights conferred by this Act on annual of non-registration of the copyright.
In Glaxo Orthopedic U.K. Ltd. v. Samrat Pharma the Delhi Aerial Cloister went into this affair in a absolutely altered ambience in the ablaze of one of the defenses aloft by the actor therein, back it claimed to accept acquired absorb allotment for the impugned carton/label. Apropos to Area 45 of the Act, the Cloister empiric that from a credible annual of the said section, it is credible that it is arbitrary for any columnist to administer for the allotment of absorb and that allotment as such does not advise any rights. Apropos to Sections 13 and 17 of the Act, the Cloister went on to beam that the alone affirmation listed beneath Area 13 is that of boldness and already that stands fulfilled, buying in the aboriginal assignment is bestowed by advantage of Area 17 apprehend with Area 2(1)(d) (which defines “author”) of the Act. The Cloister afresh went on to injunct the actor admitting its absorb allotment advertence that the impugned carton/label registered by the actor was annihilation but a archetype of the plaintiff’s registered labels, that were above-mentioned in point of time.
A actuality bearings agnate to that in Radha Kishna Sinha (supra), arose afore the Orissa Aerial Cloister in Brundaban Sahu v. B. Rajendra Subudhi. This time, however, while apropos to Sections 16, 44, 45 and 48 of the Act, the Orissa Aerial Cloister captivated that one cannot affirmation and advance any absorb unless the aforementioned has been registered with the Registrar of Copyrights. Celebratory that the Magistrate had committed gross absurdity in demography cognizance of the answerability beneath Area 63 of the Act in the absence of any absorb allotment in favour of the complainant, the Cloister quashed the bent affairs instituted by it. Interestingly, none of the beforehand decisions of altered Aerial Courts, including that of Radha Kishna Sinha (supra), were referred to or cited afore the Orissa Aerial Court.
Agreeing with the observations of the Madras Aerial Court, Calcutta Aerial Court, Allahabad Aerial Cloister and Kerala Aerial Cloister in A. Sundarasan (supra), Manojah Cine Productions (supra), Satsang (supra), Nav Sahitya Prakash (supra) and Kumari Kanaka (supra) respectively, the Division Bench of Kerala Aerial Cloister R. Madhavan vs. S.K. Nayar common that the appropriate to sue for absorb contravention beneath the Act is not abased aloft allotment of the copyright. While accomplishing so, the Kerala Aerial Cloister additionally took agenda of the observations fabricated in Mishra Bandhu Karyalaya (supra) and absolutely said that the said case had been abominably decided.
To agnate aftereffect is the accommodation of the Aerial Cloister of Andhra Pradesh in K. Marari v. Muppala Ranganayakamma, wherein the Cloister bidding its acceding with the observations of Calcutta Aerial Court, Madras Aerial Cloister and Allahabad Aerial Cloister in Satsang (supra), Manojah Cine Productions (supra) and Nav Sahitya Prakash (supra) and captivated that the allotment of absorb is not binding beneath the Act. The Cloister went on to appellation the observations in Mishra Bandhu Karyalaya (supra) as “obiter” and remarked that the said accommodation did not lay bottomward the actual law.
The catechism whether bent case for absorb contravention is arguable in the absence of absorb allotment was additionally referred to the Full Bench of the Aerial Cloister of Madhya Pradesh (Jabalpur Bench) In K.C. Bokadia and Anr. vs. Dinesh Chandra Dubey. The Full Bench took agenda of and cited with approval, the observations fabricated by the Aerial Courts of Calcutta, Allahabad, Madras, Kerala Patna and Delhi in Satsang (supra), Nav Sahitya Prakash (supra), Manojah Cine Productions (supra), R. Madhavan (supra) Radha Kishna Sinha (supra), and Glaxo (supra) and remarked that a accurate assay of the arrangement and the accoutrement of the Act does not acknowledge any aldermanic ambition to accomplish allotment of absorb binding or to booty abroad civilian or bent remedies in the accident of non-registration of copyright. Advertence that the buying of the absorb is a analytic aftereffect of authorship, the Full Bench empiric that the catechism of applying for or authoritative entries in the annals of copyrights will appear alone if there exists a assignment in which absorb subsists.
Referring to the observations in Mishra Bandhu Karyalaya (supra) as “obiter dicta”, the Full Bench captivated that the said case did not lay bottomward the actual law. Commenting that it is the allotment which follows the absorb and not vice-versa, the Full Bench ultimately answered the advertence by captivation that bent case of absorb is acceptable afterwards any allotment beneath Area 45 of the Act.
This affair afresh came up for appliance afore the Calcutta Aerial Cloister in Zahir Ahmed v. Azam Khan in a address gluttonous abolishment of the bent affairs accomplished beneath Area 63 of the Act in the absence of any absorb allotment in favour of the complainant. Cogent its acceding with the observations of the Aerial Courts of Madras, Calcutta, Allahabad Kerala and Delhi in Manojah Cine Productions (supra), Satsang (supra), Nav Sahitya Prakash (supra), R. Madhavan (supra) and Glaxo (supra), the Calcutta Aerial Cloister common that allotment of Absorb is alternative beneath the Act and not mandatory. Advertence that allotment is not a pre-requisite for accretion of a copyright, the Cloister captivated that non-registration of absorb does not disentitle the absorb buyer from instituting an activity for infringement. It is pertinent to acknowledgment actuality that the accommodation of the Orissa Aerial Cloister in Brundaban Sahu (supra) was additionally cited afore the Calcutta Aerial Cloister in this case. However, the Cloister did not accede with the same.
In Burroughs Wellcome (India) Ltd. v. Uni-Sole Pvt. Ltd. and Ors., the Bombay Aerial Cloister took a appearance that Area 45 of the Act is an enabling accouterment which provides for allotment of assignment in which absorb exists. However, the Cloister captivated that, there is annihilation beneath this Area or for that amount the Act to advance that the allotment is activity antecedent to the affluence of or accretion of copyright. However, in Gulfam Exporters and Ors. V. Sayed Hamid and Ors., while ambidextrous with a address gluttonous abolishment of the bent affairs accomplished inter alia beneath Area 63 of the Act in the absence of any absorb allotment in favour of the complainant, the Bombay Aerial Cloister disqualified that in the absence of a absorb registration, bent affairs beneath the Act cannot lie. In accomplishing so, the Cloister relied aloft and bidding its acceding with the accommodation of the Orissa Aerial Cloister in Brundaban Sahu (supra). The beforehand accommodation of the Bombay Aerial Cloister in Burroughs Wellcome (supra) was not brought to the Court’s apprehension in this case. The accommodation in Burroughs Wellcome (supra) was about cited with approval by the Bombay aerial Cloister in Asian Paints (I) Ltd. v. Jaikishan Paints & Allied Products.
In Rajesh Masrani Vs. Tahiliani Design Pvt. Ltd., a Division Bench of the Delhi Aerial Court, while cogent its acceding with the observations of the Aerial Courts of Calcutta, Allahabad and Kerala in Satsang (supra), Nav Sahitya Prakash (supra) and R. Madhavan (supra), common that allotment of absorb is alternative beneath the Act and not mandatory.
Then came the accommodation of the Bombay Aerial Cloister (Nagpur Bench) in Dhiraj Dharamdas Dewani v. Sonal Info Systems Pvt. Ltd., wherein, while apropos to the decisions of Aerial Courts of Madhya Pradesh, Kerala and Orissa in K.C. Bokadia (supra), R. Madhavan (supra) and Brundaban Sahu (supra) respectively, the Bombay Aerial Cloister empiric that in the ambience of Area 51 of the Act, the chat “may” in Area 45(1) of the Act has to be apprehend to beggarly that if an buyer of a absorb is acquisitive of invoking the civilian and bent remedies beneath the Act, afresh he charge accept a absorb registration. The Cloister additionally empiric that ability of buying of absorb in a assignment cannot be attributed to an infringer unless the accoutrement of the Act apropos allotment of absorb etc., are complied with. The Cloister afresh went on to beam that to authority contrarily can embroil an innocent actuality (not acquainted of absorb buying or registration) in civilian and bent proceedings, which could never be the ambition of the legislature.
It is pertinent to accompaniment actuality that the beforehand decisions of the Bombay Aerial Cloister in Burroughs Wellcome (supra) and Asian Paints (supra) were not brought to the Court’s apprehension in this case.
This accommodation was challenged afore the Supreme Cloister of India by way of a Special Leave Address (SLP). The Supreme Cloister absolved the SLP advertence that there is no absurdity in the adjustment anesthetized by the Bombay Aerial Court. That said, the Supreme Cloister absitively to leave the catechism of law accessible for the future.
In Laxmi Snacks Pvt. Ltd. v. Akshar Food Products, this affair afresh circumscribed up afore the Gujarat Aerial Cloister in an address arising out of the adjournment of an acting admonition application. Apropos to the decisions of assorted Aerial Courts captivation that the allotment of absorb is not binding beneath the Act and additionally the accommodation of Bombay Aerial Cloister in Dhiraj Dharamdas Dewani (supra) wherein a adverse appearance was taken, the Gujarat Aerial Cloister remarked that, although the appearance taken by the Mumbai Aerial Cloister appears to be attractive, the plaintiff cannot be non-suited alone on the arena of non-registration. However, the Cloister did not go into this affair and alone empiric that this affair is an arguable one which needs consideration.
The aldermanic intent
More generally than not, the Courts endeavor to ascertain the aldermanic absorbed while interpreting any Statute and/or accouterment thereof with the aim of adopting a aphorism of architecture which effectuates the aldermanic absorbed rather than one that may defeat it. Interestingly, while adjudicating the affair whether allotment of absorb is binding beneath the Act, assorted Aerial Courts accept fabricated guesses with absorption to the accessible aldermanic intent. However, one acute development which goes to the amount of this affair and discussed below, was never brought to the absorption of any of the Aerial Courts.
On October 01, 1955, the Absorb Bill, 1955 was alien in the Rajya Sabha. Article 65 of this Bill apprehend as under:
Thus, this Article fabricated allotment of absorb binding to be accurately enforceable.
This Bill was after referred to a Collective Board of the two Houses, which was assigned the assignment of analytical the Bill and advising all-important changes therein. On November 19, 1956, this Board submitted its address to the Rajya Sabha forth with the Absorb Bill, 1956 (as adapted by the Collective Committee). As allotment of its report, the Board appropriate several changes in the Bill, including inter alia, the barter of Article 65(2) of the Bill with a new sub-clause. The Board acquainted that the aboriginal Article 65(2) around makes absorb allotment compulsatory and places an disproportionate brake on the buyer of the absorb to exercise his rights. The Board was additionally of the appearance that abounding authors are beat from instituting contravention affairs because the cloister afore which such affairs are to be instituted is anchored at a ample ambit from the abode of their accustomed residence. The Committee, accordingly, acquainted that this impediment should be removed and it charge be provided that contravention affairs may be instituted in the commune cloister aural the bounded banned of whose administration the actuality instituting the affairs commonly resides, carries on business, etc.
The Absorb Bill, 1956, as adapted and submitted by the collective committee, independent the afterward Article 61 (in abode of the aboriginal Article 65 of the 1955 Bill):
“61. Administration of cloister over affairs arising beneath this Chapter
The aloft alteration appropriate by the Collective Board was accustomed by both the Houses. Article 61, as appropriate by the Collective Committee, ultimately begin its abode in the Act in the anatomy of Area 62. However, Area 62 tactically bare sub-clause 2 of article 61 while application the additional allotment thereof as annex (2) thereof. Area 62, therefore, reads as follows:
(1) Every clothing or added civilian proceeding arising beneath this Chapter in annual of the contravention of absorb in any assignment or the contravention of any added appropriate conferred by this Act shall be instituted in the commune cloister accepting jurisdiction.
(2) For the purpose of sub-section (1), and “district cloister accepting jurisdiction” shall, admitting annihilation independent in the Code of Civilian Procedure, 1908, or any added law for the time actuality in force, accommodate a commune cloister aural the bounded banned of whose jurisdiction, at the time of the academy of the clothing or added proceeding, the actuality instituting the clothing or added proceeding or, area there are added than one such persons, any of them absolutely and voluntarily resides or carries on business or alone works for gain.
The arrangement of contest captured aloft in this area do not leave alike an atom of doubt, if any, over the aldermanic absorbed apropos the affirmation of allotment of absorb beneath the Act. Had assembly advised that the allotment of absorb is binding beneath the Act, there was no break for either House of Parliament to accede with the Article 61 of the Absorb Bill, 1956, as adapted and submitted by the collective board and accommodate the aforementioned as it is in the Act in the anatomy of Area 62. This development, in fact, leaves no ambit whatsoever for anyone to brainstorm about the aldermanic absorbed apropos the affair at hand.
India’s obligation beneath Berne Convention and TRIPS Acceding – A acute aspect that cannot be absent afterimage of
There is yet addition aspect to this issue, which is an important one.
The Berne Convention for the Aegis of Arcane and Aesthetic Works, 1886 (Berne Convention), to which India is a signatory, requires anniversary and every application accompaniment to accord according aegis to the works basal in one of the application states (that is, works the columnist of which is a civic of such a Accompaniment or works aboriginal appear in such a State) as they admission to the works of its own nationals. What is important is that in acceding of Commodity 5(2) of the Berne Convention, such a aegis cannot be subjected to any academism by the application states.
Even the Acceding on Trade-related aspects of Intellectual Property Rights (TRIPS Agreement), to which India is a signatory, mandates all affiliate states to accede with Articles 1 through 21 (except Commodity 6bis) of the Berne Convention, including Commodity 5(2) referred above.
Therefore, any estimation suggesting that one charge access a absorb allotment in India to accomplish it is article which goes adjoin one of the actual basal credo of the Berne Convention and India’s obligation thereunder and TRIPs Agreement. Needless to accompaniment that the aforementioned charge be abhorred at all costs.
The alley ahead
While best of the Aerial Courts in India accept accurately captivated that the allotment of absorb is alternative and not mandatory, there accept been a few cases, as discussed above, area assertive Aerial Courts accept taken a adverse appearance and accept captivated that allotment of absorb is binding for the purposes of enforcement. The adverse administrative precedents do accompany in an aspect of ambiguity and ambiguity on this acute issue, as is axiomatic from the observations of the Gujarat Aerial Cloister in Laxmi Snacks (supra).
One would accept accepted the Supreme Cloister of India to actually adjudge this altercation for already and all in Dhiraj Dharamdas Dewani (supra). However, that did not happen. To accomplish affairs worse, the Supreme Cloister absitively to leave this important catechism of law open, which is a absolute compound for anarchy in appearance of the adverse judgements by the assorted Aerial Courts and could actual able-bodied aftereffect in added adverse opinions in times to come. One can alone achievement that this affair would present itself for appliance afresh afore the Supreme Cloister anon and clashing on the aftermost occasion, the Supreme Cloister will actually adjudge this affair by demography into annual the aldermanic absorbed and India’s obligations beneath the Berne Convention and the TRIPs Agreement.
© Deepa Gogia, Partner, K&S Partners | Intellectual Property Attorneys
 AIR 1970 MP 261
 (1973) 2 MLJ 290
 AIR 1972 Cal 533
 (1972) Ker LR 536
 AIR 1976 Mad 22
 1981 PTC 186
 1979 CriLJ 757
 AIR 1981 All 200
 AIR 1984 Delhi 265
 AIR 1986 Ori 210
 AIR 1988 Ker 39
 1996 JLJ 63
 1996 CriLJ 290
 1999 (19) PTC 188 (Bom)
 2000 (20) PTC 496 (Bom)
 (25) PTC 735 (Bom)
 2009 (39) PTC 21
 2012 (52) PTC 458 (Bom)
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