SC Lays Down Key Tests to Differentiate Copyrighted Works from Industrial Designs

In a landmark ruling that significantly clarifies the intersection between copyrighted works and design protection in India, the Supreme Court has laid down a structured framework for distinguishing artistic works protected under the Copyright Act, 1957 from industrial designs eligible for protection under the Designs Act, 2000. This long-awaited verdict is expected to streamline legal interpretations in intellectual property disputes, particularly where the two legal regimes overlap.

Copyrighted Works: The Case in Focus

The judgment arose from a dispute involving Cryogas Equipment Pvt. Ltd. and LNG Express India Pvt. Ltd. challenging Inox India Ltd. on grounds of copyright infringement. The Supreme Court bench, comprising Justices Surya Kant and N Kotiswar Singh, upheld the Gujarat High Court’s decision in favor of Inox and directed the trial court to proceed with the suit on its merits.

The crux of the case was the interpretation of Section 15 of the Copyright Act, which limits copyright protection when artistic works are reproduced industrially and potentially fall under the category of ‘designs’ as defined in Section 2 of the Designs Act.

Two-Step Legal Framework for Determining Copyrighted Works vs. Design

Justice Surya Kant, authoring the 56-page judgment, clarified the blurred lines between artistic and industrial works through a two-pronged legal test:

• Nature of the Work: Courts must first determine whether the subject qualifies as an ‘original artistic work’ under Section 14 of the Copyright Act, or whether it is a ‘design’ derived from such a work and reproduced through an industrial process—thereby activating Section 15.
• Functional Utility Test: If a work is deemed industrial in application, the next step is to assess whether its primary purpose is aesthetic or functional. If the dominant characteristic of the work is functional and commercial rather than artistic, it falls under the Designs Act and cannot claim copyright unless registered under design law.

Section 15: The Threshold for Ceasing Copyrighted Works

Section 15 is pivotal, as it limits copyright once a work that could be registered under the Designs Act is reproduced more than 50 times through an industrial process without actual design registration. This clause prevents creators from unfairly extending monopoly rights over functional designs by claiming long-term copyright protection.

Striking a Balance Between Two IP Regimes

The verdict emphasised the legislature’s intent to distinguish between the long-term protection of purely artistic works (e.g., paintings and sculptures) and the limited-term protection of commercially oriented designs. It confirmed that the Copyright Act and the Designs Act serve complementary purposes, and courts must avoid overlapping protections that blur these boundaries.

Guidance for Future IP Litigation

The Court also stressed the importance of a case-specific inquiry, guided by statutory text, judicial precedent, and international jurisprudence, to determine the rightful classification of any contested work. This clarification is expected to greatly reduce legal uncertainty and encourage businesses to follow proper registration procedures under appropriate laws.

Conclusion

This landmark ruling by the Supreme Court establishes much-needed clarity at the intersection of copyright and design law in India. By instituting a well-defined two-step test and emphasizing the need for functional analysis, the judgment sets a precedent for future intellectual property litigation. It not only resolves prevailing ambiguities but also reinforces the distinct purposes and scopes of both the Copyright Act and the Designs Act—ultimately safeguarding the integrity of India’s IP framework. Consult a senior Copyright expert from Vakilsearch today for protection from infringement.

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Akash G Varadaraj

Content Writer at Vakilsearch

I'm Akash. G. Varadaraj, an official content writer at Vakilsearch with over four years of experience. I'm here to simplify complex legal concepts into easily accessible articles that even a layman can understand. As a regular contributor to this news portal, I aim to keep you informed in the dynamic world of law, compliance, taxation, and much more. I ensure that you get to know our Vakilsearch expert's take on every piece of news, how it can help, and what you should do.

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