🎯 Module 4 - Part 3 of 8

Rights of Copyright Owner

Explore the comprehensive bundle of rights granted to copyright owners under Section 14, understand the nature and scope of moral rights under Section 57, and learn about performer's rights under Section 38 and broadcast reproduction rights under Section 37.

1. Introduction to Copyright Rights

Copyright is often described as a "bundle of rights" because it comprises multiple distinct rights that can be separately exploited, licensed, or assigned. The Copyright Act, 1957 divides these rights into economic rights (Section 14) and moral rights (Section 57). Additionally, the Act provides related rights for performers (Section 38) and broadcasting organizations (Section 37).

💡 Bundle of Rights Concept

Unlike physical property which is unitary, copyright is divisible. An author can assign the reproduction right to one party, the translation right to another, and the film adaptation right to a third party. Each right can also be limited by territory, time, or purpose. This flexibility is fundamental to copyright commercialization.

2. Economic Rights (Section 14)

Section 14 defines copyright as the exclusive right to do or authorize the doing of certain acts in respect of a work. These rights vary depending on the type of work and represent the commercial value of copyright.

Section 14 - Meaning of Copyright

"Copyright" means the exclusive right subject to the provisions of this Act, to do or authorise the doing of any of the following acts in respect of a work or any substantial part thereof...

2.1 Rights in Literary, Dramatic and Musical Works (Section 14(a))

For literary, dramatic, and musical works, copyright includes the exclusive right to:

  • (i) Reproduction: To reproduce the work in any material form including storing it in any medium by electronic means
  • (ii) Publication: To issue copies of the work to the public (not already in circulation)
  • (iii) Public Performance: To perform the work in public or communicate it to the public
  • (iv) Film Production: To make any cinematograph film or sound recording in respect of the work
  • (v) Translation: To make any translation of the work
  • (vi) Adaptation: To make any adaptation of the work
  • (vii) Derivative Works: To do any of the above acts in relation to a translation or adaptation

2.2 Rights in Computer Programs (Section 14(b))

For computer programs, in addition to the rights under Section 14(a), there is the exclusive right:

  • To sell or give on commercial rental or offer for sale or commercial rental any copy of the computer program

This "rental right" for computer programs was added to prevent commercial exploitation through rental businesses that would undermine software sales.

2.3 Rights in Artistic Works (Section 14(c))

For artistic works, copyright includes the exclusive right to:

  • (i) Reproduction: To reproduce the work in any material form including depiction in three dimensions of a two-dimensional work or in two dimensions of a three-dimensional work
  • (ii) Communication: To communicate the work to the public
  • (iii) Publication: To issue copies of the work to the public
  • (iv) Film Inclusion: To include the work in any cinematograph film
  • (v) Adaptation: To make any adaptation of the work

2.4 Rights in Cinematograph Films (Section 14(d))

For cinematograph films, copyright includes:

  • (i) Making Copies: To make a copy of the film including a photograph of any image forming part thereof or storing it electronically
  • (ii) Sale/Rental: To sell or give on hire or offer for sale or hire any copy of the film
  • (iii) Communication: To communicate the film to the public

2.5 Rights in Sound Recordings (Section 14(e))

For sound recordings, copyright includes:

  • (i) Making Copies: To make any other sound recording embodying it including storing in electronic form
  • (ii) Sale/Rental: To sell or give on commercial rental or offer for sale or commercial rental any copy
  • (iii) Communication: To communicate the sound recording to the public
🎥 Film vs. Underlying Works

A cinematograph film contains multiple copyrights: the film itself, the underlying literary work (screenplay/script), the musical works, the sound recording, and possibly photographs. The producer owns copyright in the film, but must acquire rights in underlying works. The 2012 Amendment strengthened authors' rights to receive royalties even after assignment.

3. The Reproduction Right

The reproduction right is the most fundamental copyright right. It covers any act of making copies of the work in any material form, including electronic storage.

3.1 Scope of Reproduction

  • Physical Copies: Printing, photocopying, handwriting, photographing
  • Digital Copies: Downloading, uploading, caching, storing on hard drives, servers, cloud storage
  • Dimensional Transformation: 3D reproduction of 2D work (e.g., sculpture from drawing) and vice versa
  • Partial Reproduction: Reproducing a "substantial part" also infringes

3.2 Substantial Part Test

Section 14 provides that rights extend to "any substantial part" of the work. What constitutes "substantial" is both quantitative and qualitative:

Blackwood v. Parasuraman
AIR 1959 Mad 410 - Madras High Court

The court held that "substantial" refers to quality, not merely quantity. A small but vital or distinctive part of a work can be substantial even if it represents a small percentage of the whole. The test is whether what has been taken represents the skill, labor, and judgment of the original author.

4. Communication to Public

The right to communicate a work to the public is defined in Section 2(ff) and is crucial in the digital age where works are transmitted over networks.

Section 2(ff) - Communication to Public

"Communication to the public" means making any work or performance available for being seen or heard or otherwise enjoyed by the public directly or by any means of display or diffusion other than by issuing physical copies of it, whether simultaneously or at places and times chosen individually, regardless of whether any member of the public actually sees, hears or otherwise enjoys the work or performance so made available.

4.1 Key Elements

  • Public: Communication must be to the "public" - not private use within family/domestic circle
  • Making Available: The act of making available itself is the infringement, regardless of whether anyone actually accesses the work
  • On-Demand: Includes interactive services where users choose time and place of access (streaming services, digital downloads)
  • Broadcasting: Includes traditional broadcast and internet transmission
Super Cassettes Industries Ltd. v. Chintamani Rao
(2012) 192 DLT 321 - Delhi High Court

The court considered what constitutes "public" in the context of a marriage hall playing copyrighted music. It held that guests at a marriage function constitute "public" for copyright purposes, and playing music at such functions requires a license. The term "public" is broader than in common parlance.

5. The Adaptation Right

Section 2(a) defines adaptation with reference to different types of works. The adaptation right is critical for derivative works.

5.1 Adaptation of Literary and Dramatic Works

  • Conversion of a dramatic work into a non-dramatic work
  • Conversion of a non-dramatic work into a dramatic work
  • Re-arrangement of a literary or dramatic work
  • Abridgement of a work
  • Representation in a comic form or vice versa

5.2 Adaptation of Musical Works

Includes any arrangement or transcription of the work.

5.3 Adaptation vs. Inspiration

📚 The Thin Line

Adaptation requires permission; inspiration does not. The test is whether the new work substantially reproduces the expression of the original, or merely draws on the same ideas, themes, or style. Using the same plot outline may be permissible; using the same dialogue is not.

6. Moral Rights (Section 57)

Moral rights protect the personal, non-economic interests of authors in their works. Unlike economic rights, moral rights cannot be assigned, though they can be waived in certain circumstances. India's moral rights provisions are based on the Berne Convention Article 6bis.

Section 57 - Author's Special Rights

(1) Independently of the author's copyright and even after the assignment either wholly or partially of the said copyright, the author of a work shall have the right:

  • (a) to claim authorship of the work; and
  • (b) to restrain or claim damages in respect of any distortion, mutilation, modification or other act in relation to the said work if such distortion, mutilation, modification or other act would be prejudicial to his honour or reputation

6.1 Right of Attribution (Paternity)

The author has the right to claim authorship and to have their name associated with the work. This includes:

  • Right to be identified as author
  • Right to publish anonymously or pseudonymously
  • Right against false attribution
  • Right to have name removed from distorted works

6.2 Right of Integrity

The author has the right to prevent distortion, mutilation, or modification that would be prejudicial to their honor or reputation. Key aspects:

  • Distortion: Twisting or altering the work's meaning
  • Mutilation: Cutting or removing parts
  • Modification: Any change to the work
  • Prejudice Test: The change must actually harm honor or reputation
Amar Nath Sehgal v. Union of India
(2005) 30 PTC 253 (Del) - Delhi High Court

This landmark case involved the destruction of a bronze mural by artist Amar Nath Sehgal that was installed in Vigyan Bhawan. The Delhi High Court recognized moral rights as the "soul" of the author's work and awarded damages for violation of the right of integrity. The court held that even the owner of a work cannot destroy it in a manner that prejudices the author's honor.

6.3 Duration and Waiver

Under Section 57(2), moral rights exist for the same term as the copyright. After the author's death, these rights can be exercised by their legal representatives. The right of integrity can be waived, but not the right of attribution.

6.4 Performers' Moral Rights

The 2012 Amendment added Section 38B providing moral rights for performers, including:

  • Right to be identified as performer
  • Right against distortion prejudicial to reputation

7. Performer's Rights (Section 38)

Performers have exclusive rights in their performances under Section 38. The 2012 Amendment significantly strengthened these rights.

Section 38 - Performer's Right

Where any performer appears or engages in any performance, he shall have a special right to be known as the "performer's right" in relation to such performance.

7.1 Who is a Performer?

Section 2(qq) defines "performer" to include an actor, singer, musician, dancer, acrobat, juggler, conjurer, snake charmer, lecturer, or any other person who makes a performance.

7.2 Rights of Performers (Section 38A)

Performers have the exclusive right to:

  • Make a sound recording or visual recording of the performance
  • Reproduce the sound or visual recording
  • Issue copies to the public
  • Communicate the performance to the public
  • Sell or give on commercial rental

7.3 Duration of Performer's Rights

Under Section 38, performer's rights subsist for 50 years from the beginning of the calendar year following the year in which the performance is made.

🎶 2012 Amendment - Royalty Rights

Section 38(4) ensures that even when performers assign their rights, they retain an equal share of royalties received for any commercial use. This "inalienable right to royalties" cannot be contracted away and represents a major protection for performers, especially in the music and film industries.

8. Broadcast Reproduction Rights (Section 37)

Broadcasting organizations have exclusive rights in their broadcasts under Section 37, protecting their investment in creating and transmitting broadcast signals.

8.1 Exclusive Rights

A broadcasting organization has the exclusive right to:

  • Re-broadcast: To re-broadcast the broadcast
  • Recording: To cause the broadcast to be heard or seen by the public on payment of charges
  • Making Recordings: To make any sound recording or visual recording of the broadcast
  • Reproducing: To make reproductions of any sound or visual recording made of the broadcast
  • Communication: To communicate the broadcast to the public

8.2 Duration

Broadcast reproduction rights subsist for 25 years from the beginning of the calendar year following the year in which the broadcast is made.

8.3 Sports Broadcasts

Star India Pvt. Ltd. v. Piyush Agarwal
(2013) FAO(OS) 540/2012 - Delhi High Court

The court considered broadcast reproduction rights in the context of cricket match broadcasts. It held that unauthorized retransmission of live sports broadcasts infringes broadcast reproduction rights. The case confirmed that streaming unauthorized signals through websites constitutes infringement of Section 37 rights.

Part 3 Quiz: Rights of Copyright Owner

Test your understanding of copyright owner rights with these 10 questions

Question 1 of 10
Under Section 14(a), the exclusive rights in a literary work include all of the following EXCEPT:
  • To reproduce the work in any material form
  • To claim authorship of the work at all times
  • To make any translation of the work
  • To communicate the work to the public
Correct Answer: B

The right to claim authorship is a moral right under Section 57, not an economic right under Section 14. Section 14(a) covers economic rights including reproduction, publication, public performance, film production, translation, and adaptation.

Question 2 of 10
The moral rights under Section 57 include:
  • Right to receive royalties and right of reproduction
  • Right of distribution and right of public performance
  • Right of attribution (paternity) and right of integrity
  • Right of translation and right of adaptation
Correct Answer: C

Section 57 provides two moral rights: (a) the right to claim authorship (attribution/paternity) and (b) the right to restrain distortion, mutilation, or modification prejudicial to honor or reputation (integrity). These are personal rights that exist independently of economic rights.

Question 3 of 10
In Amar Nath Sehgal v. Union of India, the Delhi High Court held that:
  • Destruction of artwork can violate the author's moral right of integrity
  • Government works have no moral rights protection
  • Moral rights expire after 25 years
  • Only living authors can claim moral rights
Correct Answer: A

In this landmark case, the court held that even the owner of an artwork cannot destroy it in a manner that prejudices the author's honor or reputation. The court described moral rights as the "soul" of the author's work and awarded damages for violation of the integrity right through destruction of Sehgal's mural.

Question 4 of 10
"Communication to the public" under Section 2(ff) includes:
  • Only traditional broadcasting over airwaves
  • Only theatrical exhibition
  • Only distribution of physical copies
  • Making the work available for on-demand access regardless of whether anyone actually accesses it
Correct Answer: D

Section 2(ff) broadly defines "communication to the public" to include making available "at places and times chosen individually" (on-demand), "regardless of whether any member of the public actually sees, hears or otherwise enjoys the work." This covers streaming services, digital downloads, and online availability.

Question 5 of 10
Under Section 38A, performers have exclusive rights including:
  • Only the right to be credited
  • Rights to make recordings, reproduce, communicate, and sell copies of their performance
  • Only moral rights, no economic rights
  • Rights only if they are employees
Correct Answer: B

Section 38A grants performers comprehensive economic rights including: making sound/visual recordings, reproducing recordings, issuing copies to the public, communicating to the public, and selling or renting copies. The 2012 Amendment also added moral rights for performers under Section 38B.

Question 6 of 10
The 2012 Amendment introduced Section 38(4) which provides that:
  • Performers cannot assign their rights
  • Performers' rights expire after 25 years
  • Performers retain an equal share of royalties even after assigning their rights
  • Only film performers have exclusive rights
Correct Answer: C

Section 38(4) provides that even when performers assign their rights, they retain an equal share of royalties for any utilization of their performance. This inalienable right to royalties protects performers from being completely bought out and ensures ongoing compensation for commercial exploitation.

Question 7 of 10
Broadcast reproduction rights under Section 37 subsist for:
  • 25 years from the beginning of the calendar year following the broadcast
  • 60 years from the broadcast
  • 50 years from the broadcaster's dissolution
  • Perpetually
Correct Answer: A

Section 37(2) provides that broadcast reproduction rights subsist for 25 years from the beginning of the calendar year following the year in which the broadcast is made. This is shorter than copyright in works (60 years) reflecting the different nature of broadcast rights.

Question 8 of 10
The "substantial part" test for reproduction infringement considers:
  • Only the quantity of material copied
  • Only the commercial value of what was copied
  • Only whether the copied portion was on a separate page
  • Both the quality and quantity of what was copied, with emphasis on the skill and labor of the original author
Correct Answer: D

The substantial part test is both quantitative and qualitative. Even a small portion can be "substantial" if it represents the skill, labor, and judgment of the original author - the heart or essence of the work. As established in Blackwood v. Parasuraman, quality often matters more than mere quantity.

Question 9 of 10
For computer programs, Section 14(b) provides an additional right not available for other literary works:
  • The right to prevent decompilation
  • The right to sell or give on commercial rental
  • The right to prevent private use
  • The right to perpetual protection
Correct Answer: B

Section 14(b) provides that for computer programs, copyright includes the right "to sell or give on commercial rental or offer for sale or for commercial rental any copy." This rental right was added specifically for software to prevent commercial exploitation through rental businesses that would undermine software sales.

Question 10 of 10
Which of the following statements about moral rights is TRUE?
  • Moral rights can be fully assigned like economic rights
  • Moral rights expire when copyright is assigned
  • Moral rights exist independently of copyright and survive even after assignment of economic rights
  • Moral rights exist only for cinematograph films
Correct Answer: C

Section 57(1) explicitly states that moral rights exist "independently of the author's copyright and even after the assignment either wholly or partially of the said copyright." The author retains moral rights regardless of who owns the economic rights. The right of attribution cannot be waived; the right of integrity may be waived in limited circumstances.