Written by: Prakhar Rai, Advocate | Founder, My Legal Pal | Enrolled with the Bar Council of India | NLSIU Bangalore alumnus | Contracts and technology lawyer in India
Last reviewed: 18 October 2026, against the Copyright Act, 1957 (text as published by the Copyright Office, Government of India)
The short answer
If your software is written in India, or licensed by an Indian owner, the Indian Copyright Act, 1957 decides who owns it and whether your licence is valid, whatever law your contract says governs. A clause copied from a US or UK template can be perfectly good under US or UK law and still leave a gap under Indian law.
Four gaps account for most of the damage:
- Section 19 is not satisfied. An Indian assignment must be in writing, signed, and must identify the work, the rights, the duration and the territory. It should also state the consideration. If duration is silent, the law reads it as five years. If territory is silent, the law reads it as India only.
- No assignment at all for a contractor. Indian law has no general “work made for hire” rule for software. Section 17(b) gives the commissioner first ownership only for photographs, paintings, portraits, engravings and cinematograph films. Code is not on that list, so the developer who wrote it is the first owner until a valid written assignment moves the rights.
- Employees and the chain behind them. Section 17(c) gives an employer first ownership of work made under a contract of service. That helps when the developer is on the payroll of the right entity. It does nothing for your own title if the employer is an Indian vendor, an employer-of-record or your own Indian subsidiary, and nobody has assigned the rights onward in Section 19 form.
- Moral rights, licences and stamping are ignored. Section 57 survives assignment. Section 30A applies the Section 19 rules to licences. An unstamped or wrongly stamped document can be refused as evidence in an Indian court until the duty is paid.
This article is limited to India. It does not repeat the general clause-by-clause guide on our software development agreement template or the basic licence-versus-assignment explainer in our software licensing agreements guide. It sits underneath both and answers one narrow question: what must an agreement contain so that, under the Indian Copyright Act, there is no hole in your title or your licence?
Why a US or UK clause leaves a gap in India
A typical US-style clause says something like: “All work product is a work made for hire under the US Copyright Act and, to the extent it is not, Contractor hereby assigns all right, title and interest to Client.”
That is a sensible clause under US law. Work-made-for-hire status for a contractor is narrow there too, so the fallback assignment does the real work, and under 17 U.S.C. section 204(a) a US assignment needs a signed writing. If you want the US side explained, our work for hire versus independent contractor guide covers it. I am not a US lawyer, and for questions of US law you should work with US-qualified counsel.
The gap appears when the developer, the code and the place of performance are all in India. An Indian court asked to decide who owns the copyright will look at the Indian Act. In my view it is unlikely to be satisfied with a clause that never mentions Section 19, because the Act sets formalities for assignments, and a court has to be able to read duration, territory and consideration out of the document.
I want to be careful about what is settled and what is not. The Act’s wording on assignment formalities is clear. How far a court will let a foreign governing-law clause displace those formalities for an Indian-authored work is not something I have found a clear decision on. So I treat the Indian formalities as mandatory in practice and draft to satisfy both laws at once. That costs one extra page and removes the argument.
US clause against Indian requirement
| What the US-style clause says | What the Indian Copyright Act asks for | The gap |
|---|---|---|
| “Work made for hire” | No general work-for-hire rule. Section 17(c) covers employees only. Section 17(b) covers photographs, paintings, portraits, engravings and films, not software | A contractor-written codebase is not yours on day one |
| “Contractor hereby assigns all rights” | Section 19(1): in writing, signed by the assignor | Usually met, but check that the right person signed |
| Silent on duration | Section 19(2) requires it to be identified; Section 19(5) fills a silence with five years | Rights may expire while you still rely on the code |
| Silent on territory | Section 19(2) requires it; Section 19(6) fills a silence with India | Your US and EU rights may not exist |
| “For good and valuable consideration” | Section 19(3): the assignment must specify the royalty and any other consideration | A court can treat the assignment as incomplete |
| Assigns “all future works” in one clause | Section 18(1): an assignment of a future work takes effect only when the work comes into existence | Nothing may have passed yet when the dispute starts |
| No mention of non-exercise | Section 19(4): rights are treated as lapsed if not exercised within one year, unless the assignment says otherwise | A shelved project can lose its rights |
| No moral rights clause | Section 57: the author keeps rights to claim authorship and to object to distortion that harms honour or reputation | The developer retains a right you did not account for |
Who owns software written in India by default
The answer depends on who the developer is to the person who paid for the work.
| Developer is… | First owner under the Act | What you still need |
|---|---|---|
| Your direct employee in India (contract of service) | The employer, under Section 17(c), unless the contract says otherwise | An express IP clause, so the point is not argued. Rights written outside the course of employment are a separate question |
| An employee of an Indian IT vendor you hire | The vendor, under Section 17(c) | A Section 19 assignment from the vendor to you |
| An employee of an employer-of-record (EOR) | The EOR, not you | A Section 19 assignment from the EOR to you, and IP clauses in the EOR’s employee contracts |
| An employee of your Indian subsidiary | The subsidiary | An intra-group assignment from the subsidiary to the parent, signed, with duration, territory and consideration, and correctly stamped |
| An independent freelancer or contractor | The freelancer, because Section 17(b) does not cover software | A Section 19 assignment from the freelancer |
| A freelancer engaged by your vendor | That freelancer | An assignment from the freelancer to the vendor, and one from the vendor to you |
| An AI tool producing code | Unsettled. Section 2(d)(vi) names “the person who causes the work to be created” for computer-generated works | A contract that requires disclosure of AI use and warrants the rights that exist |
Two points in that table deserve more weight than they usually get.
The chain matters, not just the last link. An assignment from your vendor to you transfers only what your vendor owned. If a freelancer wrote a module and never assigned it to the vendor, the vendor had nothing to pass to you for that module. In a diligence exercise this is the first thing a buyer’s lawyer tests, and it is cheap to fix before delivery and expensive to fix after a falling out.
Employment status is a question of facts, not a label. Indian courts look at the real relationship, mainly control, to decide whether someone is under a contract of service. A person called a “consultant” who works fixed hours on your tools under your direction may be an employee, and a person called an employee who runs their own business may not be. I cover the test in our guide to independent contractors and employees in India. For IP, the safest position is to draft as if the label might be wrong: include an assignment clause that works whichever way the facts fall.
Employer-of-record and subsidiary structures
Foreign companies often use an EOR or a captive Indian subsidiary so that developers sit on an Indian payroll. This is a sound way to hire. It also changes the ownership analysis in a way many contracts miss.
Because the EOR or the subsidiary is the employer, Section 17(c) makes that entity the first owner of what the employee writes for you. You, as the foreign parent or client, are a third party. You need a written, signed assignment from that entity that meets Section 19. If the EOR agreement is a standard services contract and says only that “Client owns all deliverables”, I would not treat that as enough. Check that it names the work, the rights, the duration and the territory and states the consideration. If the entity is a subsidiary, the assignment to the parent should also be looked at by your tax advisers, which is outside this article.
The Section 19 compliance checklist
This is the working part of the article. Each point maps to the text of the Act.
- Writing and signature (Section 19(1)). An assignment is not valid unless it is in writing and signed by the assignor or their duly authorised agent. Confirm the signatory has authority. A software company’s signing authority sits with a director or an authorised officer, not any engineer.
- Identify the work (Section 19(2)). Describe the deliverables. For a software project, attach a schedule that names the application, modules, source code, object code, documentation, designs and database schemas. “All work product” alone is weak.
- Identify the rights (Section 19(2)). Say which Section 14 rights pass. For a full buy-out, say all of them, including the right to reproduce, adapt, translate and communicate to the public.
- State the duration (Section 19(2)). Write “for the full term of copyright” or a stated period. If you stay silent, Section 19(5) fixes five years.
- State the territory (Section 19(2)). Write “throughout the world”. If you stay silent, Section 19(6) fixes India.
- State the consideration (Section 19(3)). Name the royalty and any other consideration. In a fixed-fee development contract, point to the fee schedule and say the fee is the full consideration.
- Switch off the one-year lapse (Section 19(4)). If the assignee does not exercise the rights within one year, they are treated as lapsed, unless the assignment says otherwise. Add: “The Assignee’s rights shall not lapse under section 19(4) for non-exercise.”
- Deal with future works (Section 18(1)). An assignment of a work not yet in existence takes effect when the work comes into existence. Use present-tense words (“hereby assigns”) and add a duty to sign a short confirmatory assignment at each delivery or milestone acceptance. That gives you a dated, signed document for every release.
- Mention the Act by name. I add a sentence saying the parties intend the clause to satisfy section 19 of the Copyright Act, 1957. It does not change the law, but it shows intent and tells a judge where to look.
- Cover moral rights (Section 57). Include a consent and non-assertion clause. See below for why I hedge on its effect.
- List contributors and subcontractors. Require the vendor to name everyone who writes code and to obtain assignments from them before the work is delivered.
- Carve out background IP clearly. Pre-existing tools, libraries and frameworks usually stay with the developer. License them to you in a Section 30A-compliant way: perpetual, worldwide, irrevocable and sub-licensable where needed.
- Deal with open source. Require a list of third-party and open-source components with their licences. Copyleft licences can attach obligations to your product that no assignment can remove.
- Stamp the document correctly. See the stamping section below.
- Keep the originals. Keep wet-ink or properly e-signed copies of the signed assignments, the schedules and the confirmatory deeds.
What the courts have said about silence
The leading Indian decision on the duration and territory defaults is Pine Labs Pvt. Ltd. v. Gemalto Terminals India Ltd., decided by a Division Bench of the Delhi High Court on 3 August 2011 (reported as 2011 SCC OnLine Del 5719). The agreement in that case was silent on duration and territory. The Bench held that the words used operated as a present assignment, and that the silence meant the statutory defaults of Sections 19(5) and 19(6) applied. It did not accept the Single Judge’s reasoning that an equitable assignment arose from the contract.
The practical lesson is simple and does not depend on how later decisions treat express words such as “perpetual” or “worldwide”. If you rely on the court to fill in your duration and territory, it will use the statutory figures. Write them in.
Licensing software in India: Sections 30 and 30A
Everything above concerns ownership. A licence is a different instrument, and the Act treats it with the same care.
- Section 30 allows the owner of copyright, or a prospective owner, to grant an interest in the right by licence, and the licence must be in writing signed by the owner or their duly authorised agent.
- Section 30A applies Sections 19 and 19A to licences, with the necessary changes. So the identification of the work, rights, duration and territory, the statement of consideration and the default rules apply to licences too.
The result for a foreign licensee is easy to miss. If an Indian software owner licenses its product to a US or UK customer under a licence that says nothing about territory, the default under the Act points to India. The licence may not cover the customer’s use outside India. State the territory, state the duration, and say whether the licence is exclusive, sole or non-exclusive.
A few other points specific to Indian licensing:
- Click-wrap and e-signature. The Information Technology Act, 2000 treats electronic records and electronic signatures as capable of satisfying a legal requirement of writing and signature (sections 4 and 5, and section 10A for contracts formed electronically). A properly built click-wrap with recorded assent can therefore satisfy Section 30. The weaker point is usually the content: a click-wrap that is silent on territory and duration has the same defaults.
- Lawful possessor rights. Section 52(1)(aa) lets the lawful possessor of a computer programme make back-up copies and adaptations needed to use it for its intended purpose. Do not draft a licence that tries to take that away without thinking about whether it can.
- Software as a licence, not a sale. The tax characterisation of software payments is a separate field. The Supreme Court has addressed whether payments for software licences are royalty for tax purposes, but I leave tax and GST to your accountants, and nothing here is tax advice.
- SaaS. Where the customer never receives a copy, the legal footing is the service contract plus the provider’s licence of access. The same ideas about territory and duration still apply. Our SaaS agreement drafting page and SaaS agreement template cover the commercial terms.
Moral rights under Section 57
Section 57 gives an author two rights that remain even after the copyright is assigned: the right to claim authorship, and the right to restrain or claim damages for distortion, mutilation or modification of the work that would harm the author’s honour or reputation. The proviso excludes adaptations that are permitted under Section 52(1)(aa), which is the lawful-possessor provision for computer programmes.
Indian courts have taken moral rights seriously in other creative fields. Mannu Bhandari v. Kala Vikas Pictures (AIR 1987 Delhi 13) and Amar Nath Sehgal v. Union of India (2005 SCC OnLine Del 209) are the usual references, and neither concerns software.
For commercial code, a developer asserting a right against distortion of a back-end module is unlikely. But I would not leave the point blank, for two reasons. First, a buyer’s lawyer will ask about it. Second, there is no authority I know of that settles whether a contractual waiver of moral rights is enforceable in India.
So I draft it as a layered clause: the developer consents to modification, adaptation and removal of their name, agrees not to assert Section 57 rights against the client and its successors, and, to the extent the law does not allow a full waiver, agrees not to bring claims that would interfere with the client’s normal exploitation of the software. I describe this to clients as a risk reducer, not a guarantee.
AI-assisted code, open source and other chain-of-title risks
AI-assisted and AI-generated code
Section 2(d)(vi) names the author of a computer-generated literary work as “the person who causes the work to be created”. It was written long before generative AI tools, and I have not found a decision that settles how it applies to code produced by a large language model. Our pages on AI training and copyright in India and intellectual property and AI look at the wider question.
For a contract, the useful position is practical:
- Require the developer to disclose which AI coding tools they use and for which parts of the work.
- Require a warranty that the developer has the right to assign what they deliver, and an indemnity if AI output reproduces third-party code.
- Do not promise yourself copyright in code that no human meaningfully authored. If a module is mostly machine output, your protection may come from contract, confidentiality and trade-secret style remedies rather than copyright.
Open source and background IP
An assignment covers what the developer owns. It does not give you ownership of the open-source libraries they used, and it cannot cancel a copyleft licence’s obligations. Ask for a bill of materials, check licences before release, and keep developer-owned tools outside the assignment but inside a proper licence.
Software is not patentable as such
Section 3(k) of the Patents Act, 1970 excludes a computer programme per se from patent protection. Copyright, confidentiality and contract do most of the work in India, which is another reason to get the Copyright Act formalities right. Our guide on design patent versus copyright in India explains where the boundary lies for apps and interfaces.
Non-competes will not carry the load
Section 27 of the Indian Contract Act, 1872 makes agreements in restraint of trade void, and post-termination non-competes for individual developers are generally not enforced. You cannot rely on stopping a former developer from working for a competitor. You can rely on a clean assignment, confidentiality obligations and, for trade secrets, a well-drafted NDA. I discuss the wider rules in our non-compete guide.
Stamping, signing and registration
Stamp duty. Stamp duty on a copyright assignment or software contract is set by state law and varies by state and by type of instrument. An instrument that is not duly stamped cannot ordinarily be admitted in evidence until the duty and any penalty are paid. In December 2023 a seven-judge bench of the Supreme Court held that an unstamped arbitration agreement is not void, but is inadmissible until stamped, which means the problem can be cured, at a cost and with delay. Our page on whether a contract is valid without stamp paper goes through the practical steps.
Documents signed abroad. If you sign outside India, the Indian Stamp Act, 1899 allows stamping within three months after the document is first received in India. Build that into your closing checklist, and do not leave the document in a folder for a year.
Registration. Copyright registration is optional in India, and a copyright infringement suit does not depend on it. A registration entry is prima facie evidence of the particulars in it (Section 48), which makes proof easier. Registration of an assignment is also not mandatory under the Copyright Act, though a documented trail helps. Our copyright registration advisory page covers the process.
Enforcement: where your rights will actually be tested
The developer, the servers and often the infringing copies are in India. That is why Indian law matters even where the contract chooses another law: the practical forum for an injunction is an Indian court.
- Civil remedies. Section 55 provides injunctions, damages and accounts of profits. Under Section 62, a suit can be filed in the district court where the plaintiff actually and voluntarily resides or carries on business, which helps a plaintiff who is based in India.
- Criminal remedies. Section 63 provides imprisonment from six months to three years and a fine of ₹50,000 to ₹2 lakh. Section 63B deals with knowing use of an infringing copy of a computer programme, with imprisonment from seven days to three years and a fine in the same range.
- Foreign judgments. Under Section 44A of the Code of Civil Procedure, 1908, a decree from a “reciprocating territory” can be executed in India as if it were an Indian decree. The United Kingdom, Singapore and the UAE are on the notified list. The United States is not, so a US judgment generally needs a fresh suit in India. Confirm the current notified list and limitation period before you rely on this.
- Arbitration. An award made in a New York Convention country can be enforced in India under Part II of the Arbitration and Conciliation Act, 1996, subject to the Act’s grounds for refusal. For many foreign clients, arbitration seated in Singapore or London, with an India-aware clause, gives a smoother route than a US court judgment. Our guides on arbitration versus litigation in cross-border contracts, the arbitration agreement template and how to enforce a contract in India go further.
- Indemnity. Because IP disputes can be expensive, pair the assignment with a properly drafted indemnity. See indemnity clause explained.
If a contractor is already using work you paid for, our guide on what to do when a contractor uses code or IP you paid them to build sets out the first steps.
A model India annex for software agreements
If you use a US or UK master agreement, you do not have to replace it. Attach an India annex that sits on top, and make clear that it prevails on Indian copyright matters. The wording below is illustrative. It is not a substitute for advice on your own transaction.
India Copyright Annex
- Assignment. In consideration of the Fees set out in Schedule 2, which the parties agree is full and adequate consideration, and for which no further royalty is payable, the Developer hereby assigns to the Client absolutely all copyright and all other rights in the Deliverables described in Schedule 1, including every right under section 14 of the Copyright Act, 1957.
- Duration and territory. The assignment is for the full term of copyright and applies throughout the world.
- Section 19. The parties intend this clause to satisfy section 19 of the Copyright Act, 1957. The Assignee’s rights shall not be treated as lapsed under section 19(4) for non-exercise.
- Future works. Each Deliverable vests in the Client when it comes into existence. The Developer will sign a confirmatory assignment in the form of Schedule 3 on acceptance of each Deliverable, and appoints the Client as its attorney for the limited purpose of signing it if the Developer fails to do so within [ten] days.
- Chain of title. The Developer will list every person who contributes to the Deliverables and will obtain a written assignment from each in the same terms before delivery.
- Moral rights. The Developer consents to the Client and its successors modifying, adapting and exploiting the Deliverables, and agrees not to assert rights under section 57 of the Act to the fullest extent the law allows.
- Background IP. The Developer grants the Client a perpetual, irrevocable, worldwide, royalty-free licence to use any background IP incorporated in the Deliverables, in line with section 30 and section 30A of the Act.
- Stamping. [Party] will pay the stamp duty on this Annex and will stamp it within the period allowed by law.
Two practical notes. The power of attorney in item 4 should be checked against the stamping and registration rules that apply in the signing state. And if the Developer is a company, the signatory should be someone with a board resolution or other authority to sign.
Common mistakes
| Mistake | Why it hurts | Fix |
|---|---|---|
| Copying a US “work made for hire” clause into an Indian contract | There is no general work-for-hire rule for software in India, and Section 17(b) does not list software | Add a present-tense Section 19 assignment |
| Leaving out duration and territory | Section 19(5) and (6) default to five years and India | Write “full term of copyright” and “worldwide” |
| Not stating consideration | Section 19(3) requires it | Refer to the fee schedule and call it full consideration |
| Assigning “future works” in a single early clause | Section 18(1) delays the effect until each work exists | Use confirmatory assignments on every delivery |
| Trusting the vendor without a chain of title | Freelancers behind the vendor may still own their modules | Require a contributor list and sub-assignments |
| Assuming the EOR or subsidiary structure makes you the owner | The employer is the first owner under Section 17(c) | Take a Section 19 assignment from the employer |
| Silence on territory in an Indian licence | Section 30A and Section 19(6) read it as India | State the territory and whether the licence is exclusive |
| Ignoring moral rights | Section 57 survives assignment | Use a layered consent and non-assertion clause |
| Not stamping | The document may be inadmissible until duty is paid | Stamp within the time allowed, including for documents signed abroad |
| Relying on a US court judgment | The US is not a reciprocating territory under Section 44A | Choose arbitration or plan for a fresh suit in India |
| Relying on a non-compete for protection | Section 27 of the Contract Act makes most of these void | Rely on assignment, confidentiality and trade secrets |
| No AI-tool disclosure | Authorship of machine output is unsettled | Require disclosure, warranties and an indemnity |
Where this article stops
This article covers the Indian Copyright Act’s effect on software agreements. It does not cover:
- Data protection. If the software or the developers handle personal data, the Digital Personal Data Protection Act, 2023 and the CERT-In Directions also matter. See our guide to DPDP contract compliance in India.
- Employment law. Classification, benefits and the new Labour Codes are covered in our employment pages and in the international contractor checklist.
- Tax, GST, transfer pricing and FEMA. Take advice from a chartered accountant or tax counsel.
- The commercial terms of a development contract. Scope, milestones, acceptance and warranties are in the software development agreement template.
If you want a lawyer to review a software agreement against the Indian Copyright Act, see our contract lawyers in India page or our service for technology and SaaS companies. For the IP assignment mechanics in more depth, read the IP assignment agreement guide.
Frequently asked questions
Does the governing law of my contract decide who owns the code? The governing law decides how the contract is interpreted. For code written in India, Indian courts will also look at the Indian Copyright Act when deciding who owns the copyright and whether an assignment is valid. I have not found a decision that settles how far a foreign governing-law clause can displace Section 19, so the safe course is to draft to satisfy both laws.
Is a US “work made for hire” clause enough for an Indian developer? No. India has no general work-for-hire rule for software. Section 17(b) gives a commissioner first ownership only for photographs, paintings, portraits, engravings and cinematograph films. Use a Section 19 assignment.
What happens if my assignment does not state duration or territory? Under Sections 19(5) and 19(6), the law reads the duration as five years and the territory as India. Pine Labs v. Gemalto (Delhi High Court, Division Bench, 2011) applied those defaults to a silent agreement.
Do I own code written by an Indian employee of my vendor? Not automatically. Under Section 17(c), the vendor is the first owner. You need a Section 19 assignment from the vendor.
Does an employer-of-record own the code my hire writes? In the ordinary case, yes, because the EOR is the employer. Get a written Section 19 assignment from the EOR and make sure its employee contracts contain IP clauses.
Can I license software from an Indian company to use abroad without saying so? Do not rely on silence. Section 30A applies the Section 19 defaults to licences, and the default territory is India. State the territory.
Are moral rights relevant for software? They exist under Section 57 and survive assignment. A claim against a commercial software buyer is unlikely, but the point is easy to cover with a consent and non-assertion clause. Whether a full waiver is enforceable in India is not clearly settled.
Is a click-wrap licence valid in India? The IT Act allows electronic records and signatures to satisfy writing and signature requirements. A click-wrap can satisfy Section 30, but it must still state the territory, duration and consideration.
Do I need to register copyright or the assignment? Registration is optional. It is prima facie evidence under Section 48, but an infringement suit does not depend on it.
Do I have to pay stamp duty on a software agreement? Duty depends on the state and the type of document. An unstamped document is generally inadmissible until duty and any penalty are paid. If you sign abroad, the Stamp Act gives three months from receipt in India for stamping.
Can I enforce a US judgment in India? The United States is not a reciprocating territory under Section 44A of the Code of Civil Procedure, so you would generally need a fresh suit. An arbitral award from a New York Convention country is enforceable under the Arbitration and Conciliation Act, 1996.
Who owns code produced by AI tools? The position is unsettled. Section 2(d)(vi) refers to the person who causes a computer-generated work to be created. Your contract should require disclosure of AI use and warranties about what the developer can assign.
About the author and how this article was prepared
I am Prakhar Rai, an advocate enrolled with the Bar Council of India and an alumnus of NLSIU Bangalore. I run My Legal Pal, an international team of contract lawyers with US law experience, working across several jurisdictions. We are not a US law firm, and we are not a local firm in the other countries we serve. This article is about Indian law only.
I checked the text of Sections 2, 17, 18, 19, 30, 30A, 55, 57, 63 and 63B of the Copyright Act, 1957 against the version published by the Copyright Office. I read the Division Bench judgment in Pine Labs v. Gemalto for the holding on Sections 19(5) and 19(6). I compared the points above with published guides from Indian and international sources to find what they leave out. The US-law comments are general and are not US legal advice. Other points marked as unsettled are my reading of the position, not a statement of law.
This article is general information, not legal advice for your transaction.
Legal references
Copyright Act, 1957, sections 2(d)(vi), 2(ffc), 2(o), 14, 17, 18, 19, 30, 30A, 48, 52(1)(aa), 55, 57, 62, 63 and 63B; Information Technology Act, 2000, sections 4, 5 and 10A; Indian Contract Act, 1872, section 27; Patents Act, 1970, section 3(k); Indian Stamp Act, 1899; Code of Civil Procedure, 1908, section 44A; Arbitration and Conciliation Act, 1996, Part II; Pine Labs Pvt. Ltd. v. Gemalto Terminals India Ltd., FAO(OS) 635 and 636 of 2009, Delhi High Court, 3 August 2011; Mannu Bhandari v. Kala Vikas Pictures, AIR 1987 Del 13; Amar Nath Sehgal v. Union of India, 2005 SCC OnLine Del 209; 17 U.S.C. section 204(a) (comparative point only).
