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\u2019s 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\u2019s artistic drawings.<\/p>\n
1. Do technical drawings of tractor parts qualify as artistic works under the Copyright Act?
\n2. Does manufacturing parts that resemble those drawings, without accessing them, amount to infringement?
\n3. Can reverse engineering lead to copyright violation if no drawings were copied?<\/p>\n
\u2022 The technical drawings were original and created by its employees.
\n\u2022 The defendant\u2019s parts matched the parts shown in its drawings.
\n\u2022 Claimed indirect copying or reverse engineering amounted to reproduction of the drawings.<\/p>\n
\u2022 Denied any access to or copying of the drawings.
\n\u2022 Argued that similar parts were developed independently or sourced from suppliers.
\n\u2022 Asserted that similarity alone cannot establish copying or infringement.<\/p>\n
The Court agreed that the plaintiff\u2019s 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.<\/p>\n
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.<\/p>\n
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.<\/p>\n
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.<\/p>\n
\u2022 The plaintiff\u2019s drawings are protected under copyright law.
\n\u2022 The defendant did not copy or reproduce the drawings, directly or indirectly.
\n\u2022 No copyright infringement exists.<\/p>\n
Para 26: \u201cThe burden is on the plaintiff to prove that the defendants reproduced the artistic works in material form. Mere similarity of dimensions is not enough.\u201d<\/p>\n
Para 29: \u201cThere 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.\u201d<\/p>\n
Para 33: \u201cCopying is essential to prove infringement. If the defendant manufactured the parts independently or based on market samples, it would not constitute infringement.\u201d<\/p>\n
Para 34: \u201cThe court concludes that the plaintiff has failed to establish that the artistic works were copied.\u201d<\/p><\/blockquote>\n
Case Citation<\/h5>\n
Tractors and Farm Equipment Limited vs Standard Corporation India Limited, C.S No.602 of 2007, Madras High Court, decided on 03.09.2025.<\/p>\n