Laxmi Engineering Works v PSG Industrial Institute, 1995 SCC (3) 583.
| Case Name: | Laxmi Engineering Works v. P.S.G. Industrial Institute |
| Citation | 1995 SCC (3) 583 |
| Court | Supreme Court of India |
| Date of Decision | 11th April 1995 |
| Judges | Kuldip Singh and R.M. Sahai |
Background:
The respondent, P.S.G. Industrial Institute, had filed a suit against the appellant, Laxmi Engineering Works, for infringement of copyright in their publication titled “A Textbook of Production Engineering.” The respondent had claimed that the appellant had reproduced portions of their publication without authorization. The appellant argued that the portions reproduced were common to all textbooks on the subject and that they had not infringed the respondent’s copyright.
Issue:
Whether the appellant’s reproduction of portions of the respondent’s publication constituted an infringement of the respondent’s copyright?
Decision:
The Supreme Court held that the appellant’s reproduction of portions of the respondent’s publication constituted an infringement of the respondent’s copyright.
The court noted that the portions reproduced by the appellant were not common to all textbooks on the subject, but were original to the respondent’s publication. The court also held that the appellant had not obtained permission from the respondent to reproduce the portions in question. Therefore, the court concluded that the appellant had infringed the respondent’s copyright.
The court also discussed the principle of “fair use” under copyright law. The court noted that fair use is a defense to a claim of copyright infringement, and that it applies in situations where the reproduction of copyrighted material is for the purpose of criticism, review, news reporting, teaching, scholarship, or research.
However, the court held that the appellant’s reproduction of the portions in question did not fall within the ambit of fair use.
Therefore, the court upheld the decision of the lower court and held that the appellant had infringed the respondent’s copyright.
Conclusion:
The Laxmi Engineering Works v. P.S.G. Industrial Institute case is an important case in Indian copyright law as it established the principle that the reproduction of even a portion of a copyrighted work without permission can constitute copyright infringement. The case also clarified the principle of fair use under Indian copyright law.
