Case Title: Tractors and Farm Equipment Ltd. Vs. Standard Corporation India Ltd.
Case Number: C.S No. 602 of 2007
Neutral Citation: 2025:MHC:2145
Name of Court: High Court of Judicature at Madras
Order Date: September 3, 2025
Name of Honourable Judge: The Honourable Mr. Justice Senthilkumar Ramamoorthy
Fact
The plaintiff, Tractors and Farm Equipment Limited, was established in 1961 to manufacture and sell tractors and other farm equipment in India. They were authorized by AGCO Corporation, USA, to use the trademarks and designs of Massey Ferguson. The plaintiff has been producing popular tractor models like MF 245 DI and MF 1035 DI since the early 1980s. The plaintiff claims to own the copyright to the drawings for the parts of these tractors. They state that their employees created these drawings with precise specifications and dimensions during their employment. The plaintiff asserts that they have the right to prevent others from reproducing these drawings in two or three dimensions, as the three-dimensional tractor parts are made from these two-dimensional drawings. The plaintiff alleges that the defendant, Standard Corporation India Limited, manufactured their tractor model Standard 348 by copying the plaintiff's drawings or by using a method called reverse engineering to create three-dimensional parts. Based on these claims, the plaintiff filed a lawsuit for copyright infringement and passing off.
Procedural Detail
The plaintiff filed an amended complaint under Order IV Rule 1 of the Original Side Rules and Order VII Rule 1 of the Civil Procedure Code, along with Sections 51, 55, and 62 of the Copyrights Act, 1957. The lawsuit sought a permanent injunction to prevent the defendant from infringing the plaintiff's copyright in the drawings by manufacturing and selling the Standard 348 tractor. It also sought a permanent injunction to prevent the defendant from "passing off" their tractors as those of the plaintiff. Additionally, the plaintiff requested a sum of Rs. 10,05,000 as damages, an accounting of all profits made by the defendant using the plaintiff's drawings, and the destruction of all infringing materials like drawings and catalogues. The defendant argued that the suit should be dismissed based on Section 15(1) and (2) of the Copyright Act, claiming that the copyright in a design, which is capable of being registered but is not, ceases to exist after the article to which the design is applied has been reproduced more than fifty times by an industrial process.
Based on the pleadings, the court framed 15 issues for consideration on October 24, 2016, covering aspects like passing off, copyright infringement, and the applicability of Section 15 of the Copyright Act. The plaintiff later abandoned their claims related to "passing off". Both parties presented evidence and witnesses. The plaintiff examined two witnesses, Mr. R. Muralikrishnan (PW1) and Mr. K. Mohan Kumar (PW2), and exhibited documents as Exs.P1 to P85. The defendant also examined two witnesses, Mr. Herjinder Singh Dhiman (DW1) and Mr. Sandeep Singh Kalsi (DW2).
Dispute
The core of the dispute revolves around two main points:
First, the plaintiff's claim of copyright infringement. The plaintiff alleges that the defendant's Standard 348 tractor is a copy of their MF 245 DI tractor and that the defendant reproduced the plaintiff's copyrighted two-dimensional drawings to create their three-dimensional tractor parts.
Second, the defendant's counter-argument, which states that the plaintiff's case is barred by Section 15 of the Copyright Act. This legal provision says that if a design is capable of being registered under the Designs Act but is not, the copyright for it ceases once the article to which the design is applied is reproduced more than 50 times through an industrial process. The defendant argued that the plaintiff's tractor parts fall under this category and therefore no copyright exists to be infringed. The defendant also challenged the originality of the plaintiff's drawings, stating they were based on drawings from Massey Ferguson, and argued that the plaintiff had no cause of action in this court as their tractors were sold outside India.
Detailed Reasoning Including on Judgements with Complete Citation Referred and Discussed
The court began by addressing the issue of its own jurisdiction. It concluded that since the plaintiff carried on business within the court's jurisdiction at the time of filing the suit and continues to do so, and the remedies pursued related to copyright infringement, the court did have jurisdiction.
The central part of the court's reasoning focused on the application of Section 15 of the Copyright Act. The court cited a previous judgment in A. Rudramurthy and another v. Mr. Moorthy and another, 2025 MHC 1338, which explained the meaning of Section 15. The court's analysis highlighted the difference between an "artistic work" under the Copyright Act and a "design" under the Designs Act, 2000.
According to the court's analysis, a "design" is defined in Section 2(d) of the Designs Act as something applied to an article which "appeal[s] to and are judged solely by the eye". This definition specifically excludes an "artistic work" as defined in the Copyright Act. The court noted that the definition of an "artistic work" in Section 2(c) of the Copyright Act includes a "drawing," and it does not explicitly exclude a "design" from its scope.
The court reasoned that the plaintiff's industrial drawings, exhibited as Exs. P59 to P79, fall under the category of an "artistic work" as per Section 2(c) of the Copyright Act. Crucially, the court found that these drawings would not be considered a "design" under the Designs Act because the copyright claim was for the drawings themselves, not for features that appeal "solely by the eye". The drawings were for the creation of functional components, and no claim was made regarding non-functional, visually appealing features.
The court referred to judgments from other high courts to support the plaintiff's case:
- Mody Pumps Inc. & others v. Sovereign Pumping Solutions Pvt. Ltd. & others, 2022 (91) PTC 142 (Bom): This case was cited by the plaintiff's counsel to argue that industrial drawings are not capable of being registered as designs under the Designs Act.
- Microfibres Inc. v. Girdhar & Co. and another, 2009 SCC OnLine Del 1647: The plaintiff's counsel also relied on this Delhi High Court judgment.
- Indiana Gratings Private Limited and Others v. Anand Udyog Fabricators Private Limited and others, 2009 (39) PTC 609 (Bom): This judgment was cited to support the contention that the plaintiff is entitled to protect the industrial drawings of the tractor parts under the Copyright Act.
In the context of indirect copying, the court also cited the following international judgments referred to by the plaintiff's counsel to show that copying an artistic work can be done by copying an object made from it:
- Canon Kabushiki Kaisha v. Green Cartridge Co. (Hong Kong Ltd.), 3 WLR 13
- British Leyland Motor Corp & others v. Armstrong Patents Company Ltd. & others, MANU/UKHL/0017/1986
The court found that the defendant's defense based on Section 15(2) of the Copyright Act was not applicable because the plaintiff's drawings were artistic works, not designs.
Decision
The court concluded that its jurisdiction was valid. It rejected the defendant's defense under Section 15(2) of the Copyright Act, reasoning that the plaintiff’s industrial drawings are "artistic works" and not "designs" under the relevant statutes. The court stated that the plaintiff’s drawings for functional components are not meant to appeal solely to the eye, a key requirement for a "design" under the Designs Act. Therefore, the bar on copyright protection under Section 15 of the Copyright Act did not apply. The court found that the plaintiff's lawsuit, which centered on copyright infringement of these drawings, was legally valid.
Disclaimer
The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
5 Suitable Titles for this Legal Analytical Article to be Published as Legal Research Paper
- Copyright Protection for Functional Drawings: A Deep Dive into the TAFE vs. Standard Corporation Case
- Beyond the Fifty-Copy Rule: Analyzing Copyright in Industrial Drawings under Indian Law
- Artistic Work or Functional Design? The Madras High Court's Take on Copyright and Designs Acts in Tractor Manufacturing
- The Interplay of Copyright and Designs Laws: A Legal Analysis of the Tractors and Farm Equipment Ltd. Judgment
- Intellectual Property in an Industrial Age: A Commentary on Copyright Infringement in the TAFE vs. Standard Corporation Case
