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The Idea-Expression Dichotomy In Copyright Infringement

The recent legal dispute between Humans of Bombay Stories Pvt. Ltd. ("the Plaintiff") and an opposing party ("the Defendants") before the High Court of Delhi has brought to the forefront the intricacies of the idea-expression dichotomy in copyright law. This article delves into the details of this case, examining the fundamental principles of copyright law and their application in the context of protecting creative works.

The Plaintiff's Allegations:
The Plaintiff's case revolves around the alleged infringement of various forms of content, including photographs, literary works forming the basis of stories, videos, and the distinctive manner of presenting these stories. The core of their argument is that the Defendants have imitated and copied a significant portion of their content, even replicating several images. The Plaintiff contends that this unauthorized reproduction constitutes copyright infringement.

The Defendant's Defense:
Conversely, the Defendants argue that the commonality of images between the two websites may stem from the subjects of the stories providing these images. Furthermore, the Defendants assert that the Plaintiff has also engaged in copying, pointing to instances where the Plaintiff allegedly replicated images from the Defendant's website.

The Idea-Expression Dichotomy:
Central to this legal battle is the idea-expression dichotomy inherent in copyright law. This doctrine distinguishes between the protection of ideas and the protection of the expression of those ideas. Copyright law recognizes that ideas, concepts, or themes themselves cannot be copyrighted. It is only the unique expression, the creative embodiment of these ideas, that warrants protection.

The Copyright Act of 1957:
Under Section 51 of the Copyright Act, 1957, the unauthorized copying or imitation of the expression of an idea amounts to copyright infringement. This provision safeguards the rights of creators by granting them the exclusive authority to control the reproduction and distribution of their original and creative expressions.

Court's Ruling:
In this specific case, the court has carefully examined the arguments of both parties. It observed that neither party is entitled to replicate or imitate each other's content and images. Moreover, the ruling emphasizes that this protection extends to literary content as well. As a result, the court issued an order that both parties, namely Humans of Bombay and People of India, should refrain from using each other's copyrighted works.

The Concluding Note:
The Humans of Bombay Stories Pvt. Ltd. v. People of India legal dispute provides a significant illustration of the idea-expression dichotomy in copyright law. It underscores the principle that copyright protection is not extended to abstract ideas or themes but rather to the creative expressions of those ideas. Copyright holders are granted exclusive rights to their original works, and any unauthorized replication can lead to infringement claims. The court's decision in this case reaffirms these principles, highlighting the importance of respecting the idea-expression dichotomy in copyright law and upholding the rights of creators and copyright holders.

The Case Law Discussed:
Case Titled: Humans of Bombay Stories Pvt. Ltd. Vs POI Social Media Pvt. Ltd.
Date of Judgement/Order:11/10/2023
Case No. CS(COMM) 646/2023
Neutral Citation No: 2023: DHC:7524
Name of Hon'ble Court: High Court of Delhi
Name of Hon'ble Judge: Prathiba M, Singh, H.J.

Information and discussion contained herein is being shared in the public Interest. The same should not be treated as substitute for expert advice as it is subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor - Patent and Trademark Attorney
Email: [email protected], Ph no: 9990389539

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