Case Background:
- Plaintiff: E.M. Gopalakrishna Kone
- Defendants: V. Govindan (proprietor of Sakti Karyalayam) and T.N. Subramanian (compiler of the second dictionary)
Key Issues:
- Copyright Ownership: The plaintiff alleged that he held the copyright to an English-Tamil dictionary compiled by K.V. Subbier. The defendants published a similar dictionary, which the plaintiff claimed was a direct copy.
- Originality and Compilation: The defense argued that their dictionary was an original work compiled independently by T.N. Subramanian. They contended that similarities were inevitable in works of this nature, such as dictionaries, due to common sources and the nature of language.
Court Findings:
- The court reviewed the evidence and found substantial similarities between the two dictionaries, including identical word meanings and sequences, which indicated that the defendants’ dictionary was largely copied from the plaintiff’s dictionary.
- The court dismissed the defense’s claim of originality, noting that T.N. Subramanian lacked the qualifications and experience to compile an original dictionary, unlike the experienced compiler of the plaintiff’s dictionary.
- The court ruled in favor of the plaintiff, confirming the lower court’s decree for an injunction against the defendants and awarded damages of Rs. 5,000 to the plaintiff for the infringement.
Legal Implications:
- The case highlighted that compilations like dictionaries, which involve substantial intellectual labor and originality, are protected under copyright law. Even minor variations or common sources do not justify copying significant portions of another’s work.
- It established that copyright protection extends to compilations, reinforcing that such works require skill, labor, and originality, and any unauthorized copying constitutes infringement.
This case serves as an important precedent in the realm of intellectual property law, particularly in the protection of compilations and educational materials.