Microfibres Inc. v. Girdhar & Co. & Anr.

This case involved an appeal concerning the interplay between copyright protection for artistic works and design protection for industrial products, specifically fabric designs. The appellant, Microfibres Inc., manufactured upholstery fabrics and claimed copyright protection for their original artistic designs, alleging infringement by the respondents. The lower court had ruled that the designs were registrable under the Designs Act, 2000, and therefore not entitled to copyright protection. The High Court affirmed this decision, clarifying that while original artistic works retain copyright, their industrial application as designs, especially after being reproduced more than 50 times without design registration, loses copyright protection under Section 15(2) of the Copyright Act. The court emphasized the legislative intent to provide a shorter, limited monopoly for commercial designs under the Designs Act, distinct from the longer protection for pure artistic works under the Copyright Act. Result: Appeal for copyright protection of industrially applied artistic designs dismissed; lower court's ruling on the interplay between Copyright Act and Designs Act upheld.