Introduction
In a judgment delivered on 3 September 2025, the Madras High Court adjudicated a civil suit concerning the scope of copyright protection for industrial drawings. The suit, filed by Tractors and Farm Equipment Limited (TAFE) against Standard Corporation India Limited, involved allegations of unauthorized reproduction of engineering drawings used in the manufacture of tractor parts. The central legal issues included the applicability of copyright law to functional components, the threshold for originality, and the interaction between the Copyright Act, 1957 and the Designs Act, 2000. The Court dismissed the suit but provided detailed reasoning that clarifies the legal position on these matters.
Fact of the Case
TAFE, incorporated in 1961, is engaged in the manufacture and marketing of tractors and farm equipment. It was authorized by AGCO Corporation, USA, to use the trademarks and designs associated with Massey Ferguson tractors. Among its popular models are MF 245 DI and MF 1035 DI, which have been manufactured since the early 1980s. TAFE asserted copyright over the engineering drawings used to produce these tractors and their components, stating that the drawings were created by its employees during the course of employment and included precise specifications and dimensions.
In 2007, TAFE instituted a civil suit (C.S. No. 602 of 2007) before the Madras High Court, alleging that the defendant’s tractor model, Standard 348, was a copy of its MF 245 DI model. It contended that the defendant had reproduced its drawings either directly or through reverse engineering, thereby infringing its copyright. The reliefs sought included a permanent injunction against copyright infringement and passing off, damages of ₹10,05,000, rendition of accounts, and destruction of infringing materials.
TAFE obtained leave to sue under Section 62(2) of the Copyright Act, which permits a copyright owner to file suit where they carry on business. On 24 October 2016, the Court framed fifteen issues for adjudication, covering copyright infringement, passing off, the applicability of Section 15 of the Copyright Act, and entitlement to remedies. During the course of proceedings, TAFE abandoned its claim for passing off, and the related issues were not adjudicated.
Argument in Favour
TAFE submitted that its engineering drawings qualified as “artistic works” under Section 2(c) of the Copyright Act, 1957. This provision defines artistic work to include drawings and diagrams, among other visual representations. Under Section 14(1)(c), the copyright owner has the exclusive right to reproduce the work in any material form, including converting two-dimensional drawings into three-dimensional products. TAFE contended that its drawings formed the basis for manufacturing tractor parts and components, and that the defendant had reproduced these drawings without authorization.
The plaintiff further argued that Section 15(2) of the Copyright Act, which states that copyright in a design ceases if the article is reproduced more than fifty times by an industrial process, was not applicable. According to TAFE, its drawings related to functional components and did not fall within the definition of “design” under Section 2(d) of the Designs Act, 2000. This definition excludes mechanical devices and features judged solely by the eye. Since the tractor parts were functional and not ornamental, the drawings could not be considered designs.
To establish originality, TAFE acknowledged that its drawings were based on Massey Ferguson inputs but claimed that they were modified with its own engineering contributions. These modifications included review, standardization, and production release, which satisfied the originality requirement under copyright law. The drawings were created by employees during the course of employment, further supporting TAFE’s claim of ownership.
TAFE also presented evidence of copying. The defendant’s witness (DW1) admitted during cross-examination that two-dimensional drawings are necessary to create three-dimensional products. TAFE’s expert (PW2) compared the dimensions of essential parts and found close matches between the plaintiff’s and defendant’s components. TAFE argued that the defendant must have copied its distinctive dimensions, which were not dictated by industry standards. The plaintiff relied on the principle that copying can be indirect, including by reproducing an object made from an artistic work. In support of this, it cited Canon Kabushiki Kaisha v. Green Cartridge Co. (Hong Kong Ltd.), 3 WLR 13, and British Leyland Motor Corp. v. Armstrong Patents Co., MANU/UKHL/0017/1986.
Argument Against
The defendant contended that the suit was barred under Section 15(2) of the Copyright Act. It argued that the drawings were capable of registration under the Designs Act and had been reproduced more than fifty times, thereby extinguishing copyright protection. The defendant also challenged the originality of the drawings, asserting that they were obtained from Massey Ferguson and not created by TAFE.
Regarding functionality, the defendant pointed out that a tractor contains over 5,000 parts, many of which are commonly available and governed by Bureau of Indian Standards (BIS). These standards prescribe limited tolerance ranges, meaning manufacturers are constrained in their choices. The defendant argued that similarities in dimensions were due to standardization rather than copying.
The defendant denied having access to TAFE’s confidential drawings and rejected allegations of reverse engineering. It emphasized that TAFE had failed to prove access or compel production of the defendant’s own drawings. Visual comparison of photographs showed discernible differences in certain parts, such as the hydraulic pump assembly. The defendant maintained that the similarities were coincidental and not indicative of infringement.
Court’s Decision
The Court dismissed the suit, holding that TAFE had failed to establish copyright infringement. It first confirmed jurisdiction under Section 62(2) of the Copyright Act, noting that TAFE carried out business within its territorial limits at the time of filing the suit.
On the issue of ownership and originality, the Court accepted that TAFE was the author and owner of the drawings (Exs.P59 to P79). Although the drawings were derived from Massey Ferguson inputs, they were modified with TAFE’s engineering contributions, satisfying the requirement of originality under the Copyright Act.
The Court then addressed the applicability of Section 15(2). It held that this provision applies only to “designs” as defined under Section 2(d) of the Designs Act. Since the drawings related to functional components and were not judged solely by the eye, they did not qualify as designs. Therefore, copyright protection was not barred. The Court relied on the Supreme Court’s decision in Cryogas Equipment Pvt. Ltd. v. Inox India Ltd., 2025 INSC 483, which clarified the scope of Section 15 and the definition of “design.” It also cited A. Rudramurthy v. Mr. Moorthy, 2025 MHC 1338, which reiterated that functional works are not designs under the Designs Act.
While the Court acknowledged that reproducing a two-dimensional artistic work in three dimensions falls under Section 14(1)(c), it emphasized that copyright law should not be used to monopolize functional aspects beyond what is permitted under patent or design law. Visual comparison revealed differences in parts, and the dimensional similarities were within BIS tolerance ranges. The Court found it impossible to conclude that the defendant’s parts were produced by copying TAFE’s drawings.
Finally, the Court declined to draw an adverse inference against the defendant for not producing its own drawings, holding that the burden of proof remained on the plaintiff. Since TAFE failed to discharge this burden, it was not entitled to the remedies claimed, including injunctions, damages, rendition of accounts, or destruction of materials.
Conclusion
The judgment of the Madras High Court in TAFE v. Standard Corporation observes the limits of copyright protection for industrial drawings. While the Court upheld TAFE’s ownership and originality, it found no infringement due to lack of access and the functional nature of the components. The decision observes that copyright law cannot be used to monopolize functional designs and must be interpreted in light of public domain considerations and industry standards. It also clarifies the interplay between copyright and design law, particularly the scope and limitations of Section 15 of the Copyright Act.
