Summary
In the case of Tractors and Farm Equipment Limited vs Standard Corporation India Limited, the Madras High Court ruled that manufacturing tractor parts similar to those in original engineering drawings does not amount to copyright infringement if the drawings themselves were not accessed or copied. The court stated that copyright protects the expression in the drawings, not the functional parts or their dimensions.
Copyright Infringement of Technical Drawings
Tractors and Farm Equipment Limited (TAFE) accused Standard Corporation India Limited of infringing its copyright in technical drawings of tractor parts. TAFE argued that the defendant’s Standard 348 tractor used parts identical to those in its MF 245 DI model, and that the defendant must have copied or reverse engineered them using TAFE’s artistic drawings.
Questions Before the Court
1. Do technical drawings of tractor parts qualify as artistic works under the Copyright Act?
2. Does manufacturing parts that resemble those drawings, without accessing them, amount to infringement?
3. Can reverse engineering lead to copyright violation if no drawings were copied?
Arguments Presented By the Parties
Plaintiff:
• The technical drawings were original and created by its employees.
• The defendant’s parts matched the parts shown in its drawings.
• Claimed indirect copying or reverse engineering amounted to reproduction of the drawings.
Defendant:
• Denied any access to or copying of the drawings.
• Argued that similar parts were developed independently or sourced from suppliers.
• Asserted that similarity alone cannot establish copying or infringement.
Court’s Analysis of Drawing-Based Copyright Infringement
The Court agreed that the plaintiff’s technical drawings qualify as original artistic works under Section 2(c) of the Copyright Act, and that such works are protected under Section 14. However, the court clarified that protection applies to the drawings as expressions, not to the functional ideas or parts depicted in them.
The court explained that the central requirement for infringement is copying. There must be reproduction of the artistic work, either directly or through a copy. If a similar object is created independently or by studying a product in the market, without using or accessing the original drawing, there is no infringement.
The court found that the plaintiff had not shown any evidence that the defendant had access to its drawings. It also noted that the drawings were not even marked as exhibits during trial. As a result, the court concluded that the parts may have been developed through independent design or standardisation, not by copying.
The court further ruled that even if reverse engineering was used to design the parts, this alone does not prove copyright infringement unless it involves copying the drawings themselves.
Findings
• The plaintiff’s drawings are protected under copyright law.
• The defendant did not copy or reproduce the drawings, directly or indirectly.
• No copyright infringement exists.
Relevant Paras
Para 26: “The burden is on the plaintiff to prove that the defendants reproduced the artistic works in material form. Mere similarity of dimensions is not enough.”
Para 29: “There is no evidence that the defendants had access to the drawings or that they copied the drawings. The drawings were not even marked in evidence.”
Para 33: “Copying is essential to prove infringement. If the defendant manufactured the parts independently or based on market samples, it would not constitute infringement.”
Para 34: “The court concludes that the plaintiff has failed to establish that the artistic works were copied.”
Case Citation
Tractors and Farm Equipment Limited vs Standard Corporation India Limited, C.S No.602 of 2007, Madras High Court, decided on 03.09.2025.
Indian Kanoon: http://indiankanoon.org/doc/62977925/ (Visited on 22.12.2025)
Disclaimer
This case blog is based on the author’s understanding of the judgment. Understandings and opinions of others may differ. An AI application was used to generate parts of this case blog. Views are personal.