Sanjay Kuamr Gupta & Anr. v. Sony Pictures Networks India Pvt. Ltd. & Ors.
AIR 2018 Del 169 : (2018) 251 DLT 688 : (2018) 75 PTC 562
In the High Court of Delhi
RFA 627/2018
Before Justice Valmiki J. Mehta
Decided on August 10, 2018

Relevancy of the case: Whether an idea or concept can be considered a subject of copyright infringement?

Statutes and Provisions Involved

• The Copyright Act, 1957 (Section 2(y), 37, 39A)
• The Code of Civil Procedure, 1908 (Section 96)

Relevant Facts of the Case

• The appellants created a concept named ‘Jeeto Unlimited’ and registered a copyright for it. ‘Jeeto Unlimited’ is a live TV play-along quiz show.
• The respondents are the proprietors of Kaun Banega Crorepati (KBC).
• The appellants claim they had presented their concept to the respondents, who breached their confidentiality and copied it for their show.
• The appellants contend that the Respondents should be held liable for infringement of copyright of their concept.

Prominent Arguments by the Advocates

• The appellant’s counsel pointed out similarities between the concept of Jeeto Unlimited and KBC and pleaded that they presented this concept to the respondent, who later produced their show on the same concept.
• The respondent’s counsel submitted that the appellants had no copyright over the concept used in Jeeto Unlimited and pointed out differences between both game shows.

Opinion of the Bench

• The court has relied on the principles laid down in the Supreme Court case of R.G. Anand v. Deluxe Films, stating that an idea can have no copyright.
• A concept is not a copyrighted work as defined in Section 2(y) or Sections 37 to 39A of the Copyright Act, 1957.
• One of the witnesses of the appellants produced in Trial Court had himself stated that the concept of audience/viewer engagement has been used in various television programmes.

Final Decision

• The court dismissed the appeal.

Satvik Mishra, an undergraduate student at the Rajiv Gandhi National University of Law, Punjab, prepared this case summary during his internship with The Cyber Blog India in May/June 2022.