TEAM : 28

IN

THE HON’BLE HIGH COURT

NEW DELHI

Appeal NO. /2023

(Under Section-96 of Code of Civil Procedure, 1908

IN MATTER OF:

Abhishek-----------------------------------------------------------------------------(Appellant)

VERSUS

ABC Ltd. --------------------------------------------------------------------------(Respondent 1)

Biju-----------------------------------------------------------------------------------(Respondent 2)

FOR OFFENCES CHARGED UNDER: COPYRIGHT ACT 1957

Memorial submitted
Through the council of respondent
MOHIT KUMAR
Section – H (3rd yr, 5th semester)
Exam Roll no-21309806542

1
 Table Of Contents
S.No PARTICULARS PAGE NO.

1 LIST OF ABBREVIATIONS 3

2 INDEX OF AUTHORITIES 4

3 STATEMENT OF JURISDICTION 5

4 STATEMENT OF FACTS 6

5 STATEMENT OF ISSUES 7

6 SUMMARY OF ARGUMENTS 8-9

7 ARGUMENTS ADVANCED 10-20

8 PRAYER 21

[2]
 List of Abbreviations
Hon’ble Honourable

SC Supreme Court

HC High Court

IPC,1860 Indian Penal Code,1860

SCC Supreme Court Cases

AIR All India Reporter

V Versus

Addl. Additional

No. Number

[3]
 INDEX OF AUTHORITIES

LIST OF JUDICIAL PRECEDENTS CITED

 Jeffrey’s v. Boosey (1854) 4 HCC 815

 Rogers vs. Koons 960 F.2d 301
 Donoghue Vs Allied Newspaper Ltd.; (1937) 3 ALL ER 503
 R.G Anand vs M/S. Delux Films & Ors 1978 AIR 1613
 N.T Raghunathan & Anr. V. All India Reporter Ltd., Bombay
Air 1978 Bombay 48
 Pratibha Ram v. Suraj Kumar 1985 SCR (3) 191
 Anil Gupta And Anr. vs Kunal Dasgupta And Ors. AIR 2002
Delhi 379
 Zee Telefilms Ltd. And Film And vs Sundial Communications
Pvt. Ltd. 2003 (5) BomCR 404
 Urmi Juvekar Chiang vs Global Broadcast News Limited, 2008
(2) BomCR 400
 Mansoob Haider vs. Yash Raj Films Pvt. Ltd. & Others
[(2014) 59 PTC 292].

STATUTES

1. Copyright Act, 1957

2. Code of Civil Procedure , 1908

3. Indian Penal Code, 1860

WEBSITES

www.scconline.com

www.indiankanoon.com

www.manupatra.com

BOOKS REFFERED

1.Universal’s Legal Manual on Intellectual Property Laws.

2.Case Materials Faculty of Law, Delhi University

[4]
 STATEMENT OF JURISDICTION

The hon’ble High Court has the Jurisdiction to hear the appeal in the instant matter under
section - 96 of Civil Procedure Code, 1908

96. Appeal from original decree:-

1. Save where otherwise expressly provided in the body of this Code or by any other law
for the time being in force, an appeal shall lie from every decree passed by any Court
exercising original jurisdiction the Court authorized to hear appeals from the
decisions of such Court.

i. An appeal may lie from an original decree passed ex parte.

ii. No appeal shall lie from a decree passed by the Court with the consent of parties.

2. No appeal shall lie, except on a question of law, from a decree in any suit of the
nature cognizable by Courts of Small Cause, when the amount or value of the subject-
matter of the original suit does not exceed ten thousand rupees.”

[5]
 STATEMENT OF FACTS
Plaintiff Abhishek, an acclaimed scriptwriter, conceived a plot for a reality TV programme
that required competitors to survive in adverse geographical terrains for a period of three
months. The first month was to be spent in a mountain, the next month in a forest and lastly,
in a desert.

Plaintiff, titled the work as ‘Back to Nature’. Plaintiff, with no previous experience in the TV
industry sought assistance from his college friend Biju who had experience in the TV
industry to discuss the possibility of meeting producers for adaptation of the work.

The meeting with Biju turned out to be a disappointment as Biju suggested that although the
plot was exciting but it was unrealistic for the modern human to fend all alone in adverse
geographical terrain. Biju suggested that the plot needs major changes and that he would help
him make these changes.

Biju, called after a few days and said that the plot was more unrealistic than it sounded in their
meeting and that Abhishek should drop the idea and work on something else. Abhishek did
not pursue the matter further with Biju after this response. He decided to further the story
himself and approach other producers.

After about two months, Abhishek, came across a trailer on a popular TV channel ‘X TV’
about a new programme titled ‘Man and Nature’ produced by a famous production company
‘ABC Ltd.’ The show would be a reality TV series and the auditions would be held for
couples who would be challenged to spend three months in two adverse geographical terrains,
forty-five days in a jungle and forty-five days in a mountain with no human habitation close-
by.

The very strange similarity to his work forced Abhishek to enquire about the show and his
investigation revealed that ABC Ltd. bought the script from Biju.
Plaintiff feeling aggrieved of copyright infringement filed a suit in district court against
Defendant 1 & 2. The court did not grant any relief to Plaintiff stating that there can be no
copyright in a plot as much there can be no copyright in an idea.
An appeal made via petition to the Hon’ble High Court admitted wherein provisions
contained in the Copyright Act 1957 claiming this is a violation of copyright.
The respondents defends the provision of Copyright Act 1957 on the ground that ‘Mere an
idea, theme or plot is not protected under Copyright Act 1957 but it’s form of expression’.
Copyright essentially protects the work of an author or creator and prevents others from
copying such original work. It does not bar others from coming to the same result through an
independent process.

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 STATEMENT OF ISSUES

1. Whether the plot or the idea of the show conceived by the appellant is
under the protection of the Copyrights Act, 1957?

2. Whether there is any fundamental and substantial similarity in both the

disputed shows?

3. Whether there is any criminal breach of trust done to plaintiff?

4. Whether the appellant is entitled to any relief?

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 SUMMARY OF ARGUMENTS
1. Whether the plot or the idea of the show conceived by the appellant is
under the protection of the Copyrights Act, 1957?

It is humbly submitted before this Hon’ble Court that there cannot be any registration of
copyright in idea, subject matter, themes and plots as copyright subsists only in the material
form to which the ideas are translated. Two authors may have the same idea for a book.
However the way they express themselves or the way they put down their idea in a tangible
form is what that makes a difference. It is the form in which a particular idea, which is
translated that is, protected.
The plot conceived by the appellantis not protected under the Copyright Act 1957 as states by
the district court because there can be no copyright in an idea. The plot does not fall under
any of the subject matter enumerated in section 13 of the Copyright Act 1957.
Since the copyright protection does not extend to ideas, there can be no question of its
infringement. The respondent has not infringed any copyrights and, they are the sole owners
of the show that is about to release.

2. Whether there is any fundamental and substantial similarity in both

the disputed story plots?
It is most humbly submitted before the Hon’ble Court that the fundamental story plot of both
the shows may be similar but when we look at the substantiality of both the story plots, we
find a lot of differences in the plaintiff’s and defendant’s stories for example the competitors
in the show, locations in the show, duration to spend at a location, and name of the shows.
It can be clearly seen that the idea of both the shows may be similar, i.e., both the shows are
showing adventurous and life saving skills in adverse locations but, substantially both of
them are totally different and will affect or attract totally different set of audience.

3. Whether there is any criminal breach of trust done to plaintiff?

It is most humbly submitted before the Hon’ble Court that there is no criminal breach of trust
as per section 405 of the Indian Penal Code 1860, done by the defendant in the concerned
case as criminal breach of trust takes place when there is any misappropriation of property
trusted to any person. In our case however the plaintiff sent his script to the defendant on mail
but, it would have been a criminal breach of trust if the respondent dishonestly keep the story
of the plaintiff and sell it to someone as it was. Here in the present case we can clearly see
that the respondent only took some idea/inspiration and created his own script out of that
inspiration. It is evident by human nature that it takes inspiration from something and created
his version out of that inspiration. In the present case also there is great difference in the
plaintiff and defendant’s story plot.

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 4. Whether the appellant is entitled to any relief ?

The respondent has not infringed any copyright and they are the sole owners of the show that
is about to release. The appellant has no rights in the idea or concept of a reality show based
on the survival of the fittest in adverse geographical terrains. There is no reason for giving
any order of relief in favour of the appellant.

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 ARGUMENTS ADVANCED
Issue No.1:

Whether the plot or the idea of the show conceived by the appellant is
under the protection of the Copyrights Act, 1957?

The dictionary defines copyright as "a person's exclusive right to reproduce, publish, or sells
his or her original work of authorship (as a literary, musical, dramatic, artistic, or
architectural work)."

It's important to understand that copyright law covers the "form of material expression," not
the actual concepts, ideas, techniques, or facts in a particular work. The primary goal of
copyright law is to protect the time, effort, and creativity of the work's creator. As such, the
Copyright Act gives the copyright owner certain exclusive rights.

Section 13 of the Copyright Act 1957:-

Works in which copyright subsists.—

a. Subject to the provisions of this section and the other provisions of this Act, copyright
shall subsist throughout India in the following classes of works, that is to say,—
i. original literary, dramatic, musical and artistic works;
ii. cinematograph films; and
iii. sound recording.

The plot of the show conceived by the appellant is under no protection of the Copyrights act
1957

The plot of the show conceived by the appellant is under no protection of the Copyrights Act
1957, since it is just an idea or a concept. The fundamental rule of copyright law is that there
is no copyright in an idea, but the expression of an idea is protected.1

1
Jeffrey’s v. Boosey (1854) 4 HCC 815
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The same issue has been clearly decided by the court in the landmark judgment of R.G.
Anand vs. Delux film and others2.
Issues:

1 Whether the film ‘New Delhi’ is an infringement of the copyright of play name ‘Hum
Hindustani’?

2 Whether Respondents-Defendants have infringed the copyright of the Appellants-

Plaintiffs by making the movie named ‘New Delhi’?

Arguments by the Appellants-

Mr. Andley for the Appellants argued that the lower courts have not applied the law correctly
and their order is against the settled legal principles laid down by Court in England, America
and India. The Appellants further argued that the movie is so similar to the play that it leaves
an irresistible inference and impression the film is a copy of the play. In order to prove the
similarity between the movie and play, Mr. Andley pointed out various similarities such as
the common idea of Provincialism, both have two families Punjabi and Madarasi, in both
movie and play either one of the lover tried to commit suicide but was saved by some other
person, in both movie and play the name of the father of the girl is Subramanian, both the
movie and play have their locale in New Delhi, in both movie and play, the girl is fond of
music and dance, etc. The Appellants further argued that the Respondent was aware of the
play and it was only after listening to the play they decided to make a movie on it without
their permission.

Arguments by the Respondents-

Mr. Hardyal Hardy for the Respondents argued that the lower courts have applied the law
correctly. He further argued that there is no need for this court to interfere with the findings
of the Court of facts. He refuted the claim of the similarities between the play and the movie
and contended that the movie and play both have vast dissimilarities in the context of events
and spirit.

Judgment:

The Judgment of the court was delivered by Justice Fazal Ali. The court held that

2
R.G Anand vs M/S. Delux Films & Ors 1978 AIR 1613

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 similarities between play and movie were not vast even though they both might be based on
the idea of ‘Provincialism’ but they both are very different. The play only shows one side
of ‘Provincialism’ during the marriage but the movie shows other sides also like
‘Provincialism’ during renting outhouses. The movie also shows the evil of dowry which the
play doesn’t depict. The Appellants claim was rejected by Court because the Court held that
there may be certain similarities because the idea in both movie and play is the same but it is
well- settled law that an idea cannot be copyrighted and the Court relied upon N.T.
Raghunathan& Anr. v. All India Reporter Ltd., Bomba3.The Court held that if an ordinary
person would see the play and the movie he wouldn’t deem it to be a copy of the play. There
are vast differences between the play and movie and hence the Appellants claim that their
copyright is infringed cannot sustain. The Court upheld the Judgment of the Delhi High
Court. Thus, the Court decided both the issues in favour of the Respondents and held that
there is no infringement.

Observation of the Court:-

 The Court held that there is no copyright in idea or plot but it is the way, arrangement or
expression of such an idea that can be copyrighted.
 If the source of the works is common, then some similarities are bound to be there but the
Court has to see whether such similarities are substantial to constitute infringement or not.
 If an ordinary person after seeing the work in question calls it a copy or replica of the original
work then it is infringement.
 The theme can be the same but it has to be represented differently so that it constitutes new
original work.
 If dissimilarities are more than the similarities, it shows the negative intention to copy.
 If there is clear evidence to show piracy then the violation of copyright amounts to an act of
piracy.

In another case4, Justice Brown observed, “it is the intellectual production of the author
which the copyright protects, and not the particular form which such production ultimately
takes.”

In another more recently case5 the Bombay High Court reiterated on the fact that ideas are

3
N.T. Raghunathan& Anr. v. All India Reporter Ltd., Bombay Air 1978 Bombay 48
4
Oliver Wendell Holmes v. George D. Hurst 174 U.S. 82 (1899)
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not copyrightable. The residue left behind after filtering out dissimilarities is the idea which
is not copyrightable and similarity of ideas does not lead to copyright infringement.
Similarly in the case6(commonly known as the Swayamvar Case), the Delhi High Court laid
down that an idea per se has no copyright. But if the idea is developed into a concept fledged
with adequate details, then the same is capable of registration under the Act and that the Laws
must ensure that persons who create an idea / concept or theme which is original are
rewarded for their labour.

Issue No.2:

Whether there is any fundamental and substantial similarity in both the

disputed story plots?
"The copyright does not protect the idea but it does protect the skill and the labour put in by
the authors in producing the work. A person cannot be held liable for infringement of
copyright if he has taken only the idea involved in the work and given expression to the idea
in his own way. Two authors can produce two different works from a common source of
information each of them arranging that information in his own way and using his own
language. The arrangement of the information and the language used should not be copied
from a work in which copyright subsists."

Copyright Infringement Laws

A copyright is legal protection provided to creators of original works. As soon as a work is

created, there is copyright protection, whether or not the work is ever published. Being the
copyright owner allows you exclusive rights to recreate the work, copy it, publish it, perform
it, and distribute it. If someone else engages in any of these acts without your permission, you
may file a case of copyright infringement - but only if you have first registered your
copyright.

When looking for copyright infringement, courts look to see if the exclusive rights of the
copyright owner have been violated and whether the new work is substantially similar to the
original work. Whether it was copied on purpose or by accident does not matter when

5
Mansoob Haider v. Yashraj Films [(2014) 59 PTC 292]
6
Anil Gupta V. Kunal Dasgupta AIR (2002) Delhi 379
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determining copyright infringement, only whether you copied a substantial amount of an
original work.
But sometimes copying an original work is intentional—and allowed. Creating a parody or
using the work for educational purposes are both reasons the courts have upheld as valid
under the fair use doctrine, which is an exception to copyright infringement.

Substantial Similarity

When determining whether or not someone has committed copyright infringement, the courts
use a test known as substantial similarity. However, deciding whether a work is substantially
similar is neither clear-cut nor precise. There is no exact formula, but there are standards the
court can use to reach a decision.
Looking at how much of a new work is similar to an original work can help a court decide
whether the use is trivial or warrants further examination. If only one sentence from a 300-
page book is copied, the court would most likely not find that use to be substantial.
On the other hand, if one line of a four-line poem is used, there might be an argument that a
significant amount of the original work was copied.
The second part of substantial similarity is the similarity element. The actual creative
composition has to be similar, not just the idea. Ideas cannot be copyrighted, nor can facts,
processes, ingredients, and other such information. A poem about spring flowers is an idea-
and not a unique one at that. But the exact word choice, order, punctuation, and even sentence
length are all unique creative aspects of the original work. So a court must compare the two
works to see if the new one so closely resembles the original that it was likely copied. If the
average person would confuse the new work with the original work, then there is a strong
likelihood that a court would arrive at the same conclusion.

Fair Use vs. Substantial Similarity

Fair use differs from substantial similarity because when you claim fair use, you are
admitting that you intentionally and knowingly used a copyrighted work, but for a good
reason. In this sense, fair use is a defence. The fair use doctrine allows someone to knowingly
use part of an original work, without license or permission from the copyright owner, in
particular circumstances—usually educational purposes.
Substantial similarity is not a defence at all but rather a test that courts use to determine
whether or not an alleged new work actually copies another copyrighted work that was
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created first. If you are a defendant, you do not want a court to find substantial similarity
between the works, otherwise you will be found to have committed infringement. If you are a
plaintiff, on the other hand, you do want the court to find that there is substantial similarity,
which would mean you have won your infringement case.

In the case 7 U.S. federal court gave its observation regarding similar photographs clicked by 2
photograph artists which is as follows:-

Case facts

Photographer Art Rogers shot a photograph of a couple holding a line of puppies in a row
and sold it for use in greeting cards and similar products. Internationally, renowned artist Jeff
Koons in the process of creating an exhibit on the banality of everyday items ran across
Rodgers’ photograph and used it to create a set of statues based on the image. Koons sold
several of these structures, making a significant profit. Upon discovering the copy, Rodgers
sued Koons for copyright. Koons responded by claiming fair use by parody.

Outcome

The court found the similarities between the 2 images too close, and that a “typical person”
would be able to recognize the copy. Koon’s defense was rejected under the argument that he
could have used a more generic source to make the same statement — without copying
Rogers’ work. Koons was forced to pay a monetary settlement to Rodgers.

Significance

This is one of those famous cases that encompassed a larger issue in the art world, the issue
of appropriation art. Can you build upon another’s work to create your own original piece?
And if you do so, does that constitute derivative work?

Honourable High Court of Bombay has held that the Law of Confidence is different
from Law of Copyright.
It is held that there can be no copyright of ideas or information as it is not practically possible
to infringe any copyright to adopt or appropriate ideas of another or to publish information
received from another. However, it is held that if the ideas or information have been acquired
by a person under any circumstances such as confidential information then it would be a
breach of good faith to publish them and the Court may grant injunction in such scenario.
7
Rogers vs. Koons 960 F.2d 301
[15]
It held that a Plaintiff in a breach of confidence action must address, viz. : (i) to identify
clearly the information relied on; (ii) to show that it was handed over in circumstances of
confidence; (iii) to show that it was information that could be treated as confidential; and (iv)
to show that it was used, or threatened to be used, without his licence.8

Issue No.3:

Whether there is any criminal breach of trust done to plaintiff?

Definition of trust?

It is a fiduciary relationship in which one party, known as a trustor, gives another party, the
trustee, the right to hold title to property or assets for the benefit of a third party, the
beneficiary. Trusts are established to provide legal protection for the trustor’s assets. The
entrustment of the property creates trust, and that is only an obligation annexed to the
ownership of property, which has been rising out of confidence.

Criminal breach of trust:-

Section 405 of IPC defines Criminal breach of trust:-

“Whoever, being in any manner entrusted with property, or with any dominion over property,
dishonestly misappropriates or converts to his own use that property, or dishonestly uses or
disposes of that property in violation of any direction of law prescribing the mode in which
such trust is to be discharged, or of any legal contract, express or implied, which he has
made touching the discharge of such trust, or willfully suffers any other person so to do,
commits “criminal breach of trust”.”

Essentials of criminal breach of trust:-

Entrustment with the property or entrustment with any dominion over property

Person entrusted:

1. dishonestly misappropriates that property

b) or converts to his own use,
c) or dishonestly uses that property
d) or disposes of that property
e) or willfully suffers any person.
2. In violation:
8
Zee Telefilms Ltd. And Film And vs Sundial Communications Pvt. Ltd. 2003 (5) BomCR
404

[16]
 a. Of any direction of law prescribing the mode in which such trust is to be
discharged,
b. Or of any express or implied legal contract which is made for the discharge of
such trust.

Entrustment

Necessary meaning is handing over the possession of that property for some purpose which
may not imply conferring proprietary rights.

To make it an offence there must be misappropriation by a person in whom confidence is

placed.

Property

May be movable property or immovable

It must be one which belonged to the complainant
It doesn’t matter that the complainant is the owner of it or not.

Dominion Over The Property

a) When a person supervises or exercises his control over the property

b) Or he/she is in charge of that property.

Dishonestly misappropriates or converts for his own use

The dishonest intention is the essence of this offence. Mere retention of the goods by a person
without misappropriating does not amount to the criminal breach of trust9.

Dishonestly uses or disposes of that property:

1. following four positive acts are necessary :

i. misappropriation,
ii. conversion,
iii. the user,
iv. Disposal of the property.
2. Substantial loss or appreciable loss to the owner or gain to the accused
must be there.

Trust:

9
Pratibha ram v. Suraj Kumar 1985 SCR (3) 191

[17]
An obligation towards the ownership of property arising out of confidence to manage for the
benefit of others.

Willfully suffers any other person to do so:

Acts done have been done deliberately or intentionally and not by accident or non-
intentionally.

Violation of legal contract:

A person takes a scooter on hire for 7 days further gave that scooter to Z. Z further pledges
with P against a loan of Rs. 500 returned the scooter after 5 months. A person is liable for
criminal breach of trust in violation of the contract.

In the present case it is evident by the facts that the plaintiff Abhishek has mailed only the
outline of the plot to Biju, if the plaintiff would have mailed the whole script of the show to
the defendant and the defendant would have sold the same script as it was, to the producers of
the ABC Pvt. Ltd. then the act of defendant could come under the criminal breach of trust.
Here in the present case when the defendant approached to the directors with the script idea
of Plaintiff the producers said it to be impractical and the defendant might have thought about
the idea and talked to the producers and came out with his original script based on that same
idea, but with a practical approach. In that case the script wrote by the defendant is totally his
original creation which he sold to the TV producers, which is also evident by a lot of
variations and dissimilarities in both the scripts.

To constitute the offence under Section 405 of IPC there are 2 requisites as mentioned above
but in the present problem neither the property was wholly entrusted upon the defendant and
neither the defendant misappropriated, converted or disposed his script in violation of such
trust. Instead the defendant took inspiration out of the plaintiff’s idea of adventurous
competition show and came out with his own original creation of script.

In the case10 court has clearly state as to what work would be considered as an original work
subject to copyright and mere concept or idea doesn’t amount to copyright.

The Plaintiff transformed her idea into a concept and prepared a detailed concept note
containing the concept, the form, the treatment, the problems, etc.
The said concept note prepared by the Plaintiff of the television programme titled Work in
Progress was registered with the Film Writers Association, Mumbai. The Plaintiff asserts that
the concept note is a literary work within the meaning of Section 2(o) of the Copyright Act,
1957. and that the Plaintiff has the exclusive right to reproduce the said literary work and to
make a television programme based on the same in terms of Section 14(a) of the Act.

10
Urmi Juvekar Chiang vs Global Broadcast News Limited, 2008 (2) BomCR 400

[18]
The concept note as well as the further developed concept note and the production plan, it
cannot be disputed, can be described as literary work of the Plaintiff in relation to which there
was existing copyright in her favour. Reproduction or adaptation of that work in any material
form or any substantial part thereof by the Defendants would clearly attract the action of
infringement of copyright.

In our moot problem plaintiff might mention this case but this case doesn’t resemble our
moot problem as in Urmi Juvekar Chiang v Global Broadcast News Limited 20088, the
plaintiff prepared a concept note which was a detailed literary work of her Idea and also his
idea of TV programme 'Work in Progress' was registered with the Film Writers Association
Mumbai but here in the given case Abhishek only made the outline of his plot and mailed it
to defendants which again not contribute as a literary work.
In another case11, court observed that mere idea is not subject to copyright registration and
infringement.

A person may have a brilliant idea for a story, or for a picture, or for a play, and one which,
so far as he is concerned, appears to be original, but, if he communicates that idea to an
author or a playwright or an artist, the production which is the result of the communication of
the idea to the author or the artist or the playwright is the copyright of the person who has
clothed the idea in a form, whether by means of a picture, a play, or a book, and the owner of
the idea has no rights in that product.

Therefore referring this case, we can conclude that mere idea of some literary work (idea of
TV Programme in our case) cannot be copyrighted.

Issue No. 4

11
Donoghue Vs Allied Newspaper Ltd.; (1937) 3 ALL ER 503

[19]
Whether the appellant is entitled to any relief ?

The respondent has not infringed any copyright and they are the sole owners of the show that
is about to release. The appellant has no rights in the idea or concept of a reality show based
on the survival of the fittest in adverse geographical terrains. There is no reason for giving
any order of relief in favour of the appellant

Referring the above cited cases and arguments, we can conclude that mere idea of some
literary work (idea of TV Programme in our case) cannot be copyrighted and hence the
plaintiff/appellant is not entitled to any relief.

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 PRAYER

Wherefore, in the light of the facts stated, issues raised, arguments advanced and authorities
cited, the respondent humbly prays before the hon‟ble court to kindly declare that,

1. Trial court decision be maintained and dismissed the appeal.

2. The appellant only has a mere abstract idea and not the owner of any copyright.
3. The respondents are not guilty of infringement of alleged copyright.

And the hon’ble court may be pleased to pass any such order as it may deem fit and proper in
the interest of justice, equity and good conscience.

All of which is respectfully submitted and affirmed.

Council on Behalf of Respondent

MOHIT KUMAR
Section – H (3rd yr, 5th semester)
Exam Roll no-21309806542

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