Geographical Indication as a Tool for Protection of

Traditional Knowledge with Special reference to Protection

of ‘Cashmere’ in Kashmir

Introduction

The term ‘geographical indication’ was used for the first time in the TRIPS
Agreement of the WTO, which came into force in 1995. Geographical Indication( GIs
) are defined at Article 22(1)1 of the TRIPS Agreement2. GIs may be connected
with agricultural, natural, manufactured or industrial goods.3
GI acts as a indicating device which helps producers to differentiate their products
from competing products in the market and enables them to build goodwill and a
reputation around their products4. For example Florida Oranges, Pisa silk,
Champagne, New Zealand lamb, Murano Glass, Swiss Watches, Bukhara carpets and
Kashmir Pashmina etc.5
Theoretically, the concept of traditional knowledge refers to the knowledge of and
local and indigenous communities around the world developed which has been
developed from experience and passed down from generations to generations over the
years.6GI as a regime of IP is considered to be tool for the protection of traditional
knowledge of community.7 In this project viability of GI for protection of cashmere
(pashmina) which is one expressed form of the traditional knowledge has been
examined. Pashmina is used for the shawls , stoles etc.. The characteristics of the

1
Article 22(1) says that “indications, which identify a good as originating in the territory of a
Member, or a region or a locality in that territory, where a given quality, reputation or other
characteristic of the good is essentially attributable to its geographic origin.”
2
Earlier to TRIPS Agreement some other international conventions and agreements such as the Paris
Convention, the Lisbon Agreement, Madrid Convention, contained provisions on the protection of
indication of source and appellations of origin , Cited from
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1922347 (last accessed on 1 Nov, 2011)
3
Geographical Indications of India Socio- Economic and Development Issues
http://www.aiacaonline.org/pdf/policy-briefs-geographical-indications-india-socio-economic-
development-issues.pdf (last accessed on 8th Nov. 2011)
4
Ibid p.1
5
ibid, p.5
6
Sindhu Siva Kumar and Raghuvaran Gopalan, Keeping Cashmere in Kashmir- the interface
between GI and TK, Vol. 12 Journal of Intellectual Property Rights , 2007, p 581
7
Nair L & Kumar R, Geographical Indications: A Search for Identity,,Lexis Nexis Butterworths,
New Delhi,2005

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cashmere wool in Kashmir, includes the history of the Kashmir region, as well as
traditions, culture of indigenous people , whose quality is the best in Kashmir but this
best quality wool has to confront various harms in term of commercial loss ,
lowering down the reputation and goodwill in the market due bio piracy done by the
various countries.8

Heritage of Kashmir: ‘Cashmere’ in Kashmir

The Kashmir region which is known for its beauty is also treasure of traditional
knowledge. One of such renewed expression of traditional knowledge (TK) is
Cashmere ( pashmina fabric). Pashmina is the purest form of the Cashmere9.
Cashmere is the luxuriously soft and extremely warm wool of the cashmere goats
whose origin is the Kashmir Valley there is the so-called ‘pashmina,’ which is
considered the Kashmir's best cashmere. In Kashmir, cashmere goats (Kashmir goats
or Himalayan mountain goats) are a member of Capra hircus. Pashmina is the purest
form of the Cashmere10.
The pashmina goats which live above 4500 meters high altitude produce the finest
wool. There winter temperatures that fall as low as minus 30 degrees Celsius (-22°
F)11. The growth of the fine and warm ‘pashm’ is natural for goats,living there to
adapt the harshly windy location. Pashmina is obtained from Himalayan region goats,
Capra hirus..12

8
Yamamoto Koji, Cashmere as Geographical Indications , TED Case Studies: Number 786, 2005,
available at http://www1.american.edu/ted/cashmere-gi.htm (last accessed on 5th Nov, 2011)
9
Ibid
10
This name came from Persian word ‘pashm’ which means wool when it is in woven form it called
as pashmina. Pashm has a special characteristic due to its long and fine fibres, which are as thin as “12
microns”. The natural colours of the pashmina range from white to gray, red, brown and black Cited
from Santa Barbara. Will China dominate the textile market?
http://fecolumnists.expressindia.com/full_column.php?content_id=77003 (last accessed on 23 rd Oct,
2011)
11
Santa Barbara. Will China dominate the textile market?
http://fecolumnists.expressindia.com/full_column.php?content_id=77003 (last accessed on 23 rd Oct,
2011)
12
To survive itself from the chilly winter at the high altitude, it grows incredible soft inner coat which
is six time finer then human hairs. During the summer time their underbellies are covered with two
different type of wool one is called as pahmina (cashmere) which is soft , fine. and other is thick
course outer layer cited from Cashmere, available at http://www.
ansi.okstate.edu/breeds/goats/cashmere( last accessed on 29Oct, 2011)

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Pashmina as an Expression of Geographical Indication
How to protect the traditional knowledge for steps involved for the protection of
pashimina is still a debate? Kashmir pashmina has been designated a status of GI
pursuant to an application by the Craft Development Institute established by the
handcraft ministry of textiles Government of India13 . The registration of Pashmina of
Kashmir as a geographical indication is important because India is raising the demand
along with other countries to expand the Article 23 of TRIPS14. The registration of
pashmina at the national level is essential criteria for the protection of pashmina at the
global level as well15
Article 22.1 of the TRIPS Agreement defines the geographical indication16. GI
involves certification of the origin based on the certain natural or human factors
which are particular to that region only. Thus it can be analysed that the in case of GI
product derives its reputation and the quality from that place as in case of cashmere
that is originating in the region of Kashmir , has reputation and quality which are
attributable to that place only .
The culture, history and the quality of the particular product is basis behind the claim
of the producers of pashmina in the Kashmir region. GI in their form are the ,
communication form of the TK because of this only many persons believe that the
G I is the only existing form of the protection of the traditional knowledge which is
very much associated with that region.

Pashmina (Cashmere ) as an Expression of TK

In this part I will be discussing as to how cashmere is the expression of TK.
The origin of pashmina dates back to ancient civilization. In the ancient time, often,
pashmina products which were in form of shawl, stoles, were mostly woven for self-
consumption17.

13
Das Kasturi, Protection of geographical indications: An overview of select issues with particular
reference to India CENTAD, India) available at
(http://www.centad.org/cwp_10.asp(last acccesed on 2nd Nov, 2011)
14
Article 23 :Additional Protection for Geographical Indications for Wines and Spirits
15
Kashmir gets GI for Pashmina , available at
www.lexorbis.com/Kashmir_gets_GI_for_Pashmina.htm (last accessed on 12 Nov, 2011)
16
Supra note 1
17
In due course, the pashmina products found goodwill with the royal families, kings, emperors, etc.
With this increase in recognition and demand , it became more trendy and widespread in all places. But
the notable bond of this fabric with the region, and its cultures and traditions, continues even today

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Specifically, the manufacturing of pashmina includes the following steps: Fibre
collection; fibre spinning; weaving in hand-looms; mending white pieces; washing
white pieces to remove spots, blots, dyeing; fringe and designs making; embroidery;
and ironing and packing. The fine wool is collected by local regional women who
comb it thoroughly to separate pahmina from thicker wool which is not so luxuriant
wool18.
Once this collection of wool is completed process of manufacturing begins .The
weaving process is an art, which has passed over the generations. It includes a unique
process of giving design instruction as it is in form of poem which has been recited
by head of the family in language which is unique to the family. The persons who are
following him sit behind the loom and follow the verbal instruction which are in
poetic form to create a pattern that is unknown to them until its conclusion. It takes
around six days to weave a pashmina shawl19.
Thus, the process of manufacture of the pashmina shawl which is based on the
knowledge, innovations, and practices of the local community, developed from
experience gained over the centuries and transmitted orally from generation to
generation which can be seen both in the process and the pashmina product
Therefore, it can be definitely stated that elements of traditional knowledge are
involved in the making of the pashmina.20.

Traditional Cultural Expression

Traditional Cultural Expressions (TCEs) make obvious that information includes
cultural expressions and is not limited to plant genetic resources. Such TCEs21 are:
music, weaving and pottery patterns, dance, other traditions of healing, cooking,
cleaning and dressing.

cited from Sindhu Siva Kumar and Raghuvaran Gopalan, Keeping Cashmere in Kashmir- the
interface between GI and TK, Vol. 12 Journal of Intellectual Property Rights , 2007, p.582
18
Supra note 6, p. 582.
19
Supra note 8
20
Supra note 6, p. 582
21
The idea TCEs was accepted by the United Nations Educational, Scientific and Cultural
Organization (UNESCO), Office of Nations High Commissioner for Human Rights (OHCHR) and
WIPO protects TCEs insofar as these are recognized internationally or domestically as cultural rights,
but WIPO does not itself establish an international legal protection for it. Cited from WTO,
Secretariat, The Protection of Traditional Knowledge and Folklore, Summary of the Issues Raised and
Points Made, WTO Document IP/C/W/370, 8 August 2002, [hereinafter WTO Secretariat, The
Protection of Traditional Knowledge, Summary of the Issues], p.3.

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Expressions of Culture are a most vital means of self-expression. They are living,
functional traditions, rather than a more reminder of the past. They are a potent means for
bringing people and communities together and asserting their cultural identity22.
The WIPO Intergovernmental Conference identifies TCEs23
Article 1(a)(iv) of the Substantive Provisions of the WIPO Revised Provisions for the
Protection of Traditional Cultural Expressions/Expressions of Folklore provides24.
Here intangible expression covers expressions, such as, folk poetry, folk tales
riddles, signs, words, symbols and indications; musical expressions, such as folk
songs and instrumental music25.Tangible expressions includes - productions of folk
art, in particular, drawings, paintings, carvings, sculptures, pottery, terracotta, mosaic,
woodwork, metal ware, jewelry, basket weaving, needlework, textiles, carpets,
costumes26.
TK thus is “traditional” not because it is old, but because the knowledge is created,
preserved and disseminated in the cultural traditions of particular communities27.
So here from above we can say that creation of clothing, singing, dying, and
weaving patterns, design, spiritual and expressions of culture also constitute TK.
In weaving a pashmina shawl all these expression are involved so it constitute
expression of TK.

22
Kamal Puri, “How Intellectual Property Rights Could Work Better for Developing Countries and
Poor People”, Commission on Intellectual Property Rights, Session 3: Traditional Knowledge and
Folklore, 21st – 22nd Feb, 2002, The Royal Society ,6 Carlton House Terrace, London SW1Y 5AG
Transcript.
23
As “(i) the protection and preservation of tangible and intangible cultural heritage; (ii) the
encouragement of cultural diversity; (iii) the respect for cultural rights; and (iv)the promotion of,
innovation and creativity – including that which is tradition based as ingredients of sustainable
economic development.” Cited from Intergovernmental Committee on Intellectual Property and
Genetic Resources, Traditional Knowledge and Folklore, Fifth Session, Geneva, July 7 15, 2003,
Consolidated Analysis of the Legal Protection of Traditional Cultural Expressions, Document
.Prepared by the Secretariat, WIPO Document WIPO/GRTKF/IC/5/3, 2 May 2003
24
“traditional cultural expressions” or “expressions of folklore” can be tangible expressions, such as
productions of art, in particular, drawings, designs, paintings (including body painting), carvings,
sculptures, pottery, terracotta, mosaic, woodwork, metalware, jewellery, baskets, needlework, textiles,
glassware, carpets, costumes; handicrafts; musical instruments; and architectural forms cited from
Daphne Zografos, Geographical Indications & Socio-Economic Development, Working Paper 3,
December 2008
25
Intellectual Property and Traditional Cultural Expression/Folklore, World Intellectual Property
Organisation available at
http://www.colophon.be/images/Documents_pdf/TCE%20Booklet%20no%201%20screen.pdf(last
accessed on 29, Oct, 2011)
26
ibid
27
Agrawal, A., ‘Indigenous and Scientific Knowledge: Some Critical Comments’, in: 3(3) Indigenous
Knowledge and Development Monitor, 1995, available at:
http://www.nuffic.nl/ciran/ikdm/3 3/articles/agrawal.html(last accessed on 18th Nov, 2011)

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GI as tool for protection of traditional knowledge
It can be said that TK and GIs share a common element insofar as they both protect
accumulated knowledge which is distinctive to a specific locality. Though TK
expresses the local traditions of knowledge, GIs stand for specific geographical origin
of a typical product. GIs relate a product and which is a particular to region or
locality while TK relates to a piece of information TK.28
Many countries support that the geographical indications (GIs) could be a particularly
important way of protecting products based on TK. This strategy seeks to enquire into
the unique attributes of this intellectual property tool, which could perhaps make it
more suited to protecting indigenous knowledge, especially from the perspective of a
developing country like India29.
The protection granted to GIs extends indefinitely and the possibility of collective
ownership of such rights suggest that they may be especially suitable for protecting
TK. GIs may make possible protection of the collective rights of the local and
indigenous communities in their IK, ensuring that the entire community which has
preserved the knowledge and has passed it over generations, stand to benefit from the
knowledge .30
The European Communities and their Member States have suggested that it may also
be useful to look at the possible role of GIs in achieving the goals of the Convention
on Biological Diversity (CBD)31.

28
TRIPs Art. 22.1 “Geographical Indications are, for the purpose of this Agreement, indications which
identify a good as origination in the territory of a Member, or a region or locality in that territory,
where a given quality, reputation or other characteristic of the good is essentially attributable to its
geographical origin” ..
29
Suman Sahai, Indrani Barpujari, Are Geographical Indications Better Suited to Protect Indigenous
Knowledge? A Developing Country Perspective, p. 1 available at
http://www.genecampaign.org/home_files/Gene_Briefing/Policy%20Brief-2.pdf (last accessed on 15
th oct, 2011)
30
ibid
31
The CBD recognize the existence of geographically defined areas that are regulated to achieve
objectives of conservation. Products originating and coming out from such areas may perhaps also be
identified as geographical indications, if producers decided to link their collective production standards
and related TK to conservation goals . Therefore GIs, may also be considered as as a means to
achieve TRIPS- CBD reconciliation apart from protecting TK. India is exerting pressure in the TRIPS
Council so that high quality products of importance to India based on the TK perfected over centuries
can be protected. Cited from Suman Sahai, Indrani Barpujari, Are Geographical Indications Better
Suited to Protect Indigenous Knowledge? A Developing Country Perspective, p. 1 available at
http://www.genecampaign.org/home_files/Gene_Briefing/Policy%20Brief-2.pdf (last accessed on 15
th oct, 2011)

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The GI covers certification of origin or reputation of product in that particular
territory so it has to be noted by their character and the nature , are communication
form of protection this can be one of the reason as GI as tool for the protection of
the traditional knowledge32.
From the viewpoint of protection of TK, one of the best features of the Geographical
Indications of Goods (Registration & Protection)Act, 1999 is comprehensive
definition given of GI33. This is significant in the Indian context considering the wide
variety of goods that is deserving of protection ranging from agricultural products like
Darjeeling tea ,Basmati, to manufactured goods such as Chanderi silk, Agra ka
petha, Kolhapure chappals, etc.
Section 11 of the Act provides34. Thus it can be seen that it can be tool to protect
TK . This is unlike the protection offered by a patent; after patent protection lapses,
the subject matter of protection comes into the public domain. It can be continued to
be protected indefinitely by renewing the registration when it expires after a period of
ten years. So protection of TK through GI can be continue for indefinite time period .
As per Section 2435, this feature is essential for protection of TK and to ensure that it
does not pass on to the hands of those who are not holders of the knowledge.
Section 25 of the Act36, This section is important to the protection of TK, which may
be regarded as heritage of a community or public property and ensures that it is not
locked up as the private property of one individual.

GI includes Textile
The Textile Committee of India creating awareness among various stakeholders of
Textile and Clothing sector on the benefits of GI by spreading nation wide campaign.
This Committee facilitates GI registration of the products. Some GI registrations that
the Committee has facilitated include Pochampally Ikkat, Lucknow Chikan Craft,

32
Supra note 7
33
whereby agricultural, natural and manufactured goods all come under the ambit of GI.
34
Any association of persons, producers, organization or authority established by or under the law can
apply for registration of a GI. This section facilitates protection of the collective rights of the rural and
indigenous communities in their IK.
35
A GI cannot be assigned or transmitted. The Act recognizes that a GI is a public property belonging
to the producers of the concerned goods; as such it cannot be the subject matter of assignment,
transmission, licensing, pledge, mortgage or any contract for transferring the ownership or possession
36
It says that prohibiting the registration of a GI as a trademark, tries to prevent appropriation of a
public property in the nature of a geographical indication by annindividual as a trademark, leading to
confusion in the market.

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Banaras Saree & Brocades of Uttar Pradesh etc37. So many GI application has been
made in in textile in the year 2009-201038
It is interesting to note , that out of the total 120 registered GIs so far, 80 (66%)
belongs to the handicraft category followed by agriculture 31 (26%), manufactured 7
(6%) and food stuff (2%). Out of the total 28 states and 7 union territories of India
products from only 18 states have been registered under the GI act39. So here we can
see that GI includes textile accordingly Pashmina has got GI.

Is GI is sufficient for protection of TK

In this chapter I will be discussing as to GI is not sufficient for the Protection of TK
as it is facing problem of bio piracy by different countries.
Although GI provides certain protection to the TK and TCE but still there are certain
limitation to protect the traditional knowledge.
1) A geographical indications regime to protect indigenous knowledge would only
protect and preserve only tangible TK and TCEs.
2) the knowledge connected with the geographical indication is not protected and it
remains in the public domain. As a consequence, such knowledge is open to
misappropriation by third parties40.
Because of reasons given above it can not be said that GI is sufficient for protection
of TK . As ultimately GI ultimately protects name of the product. But here traditional
in case of cashmere is related to process of production and the quality resulted from
such process of production. It may be observed that production and process of
weaving pashimina shawl is based on the knowledge of the community and is
transmitted from generation to generations are not protected by the G I as does not
protects the process of weaving pashmina. So this problem faced by the pashmina.

37
Supra note 3
38
Ibid See Annexure 1 cited from Geographical Indications of India Socio- Economic and
Development Issues http://www.aiacaonline.org/pdf/policy-briefs-geographical-indications-india-
socio-economic-development-issues.pdf (last accessed on 8th Nov. 2011)
39
Ibid , See Annexure 2 cited from Geographical Indications of India Socio- Economic and
Development Issues http://www.aiacaonline.org/pdf/policy-briefs-geographical-indications-india-
socio-economic-development-issues.pdf (last accessed on 8th Nov. 2011)
40
Daphne Zografos, Geographical Indications of India :Socio- Economic and Development Issues,
Working Paper 3, December 2008, available at http://www.aiacaonline.org/pdf/policy-briefs-
geographical-indications-india-socio-economic-development-issues.pdf(last visited on 20th Nov.,
2011)

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As an example MNC gets its on traditional knowledge which goes into the
production of pashmina they can use this knowledge and can make a shawl which not
inferior to pashmina product , GI will not prohibit this kind of bio piracy as protects
only the name of the product not the product or process41 . Thus GI granted to the
pashmina only prevents the misappropriation of name of pashmina . So it can be
concluded as GI per se is not sufficient for the production of TK in case of
pashmina42.

Current IP Regime is insufficient to protect the traditional

knowledge
Modern IP system because of the stringent requirements of originality, authorship,
material form, novelty and limited duration .While the indigenous systems of
knowledge is driven by three characteristics, trans-generational, non-materialistic
and non-exclusive or communal ownership of rights, they are created collectively.
Rights, when it comes to indigenous peoples, are not anchored to a particular
individual but they rest in a family ,clan, group or community. Basically, most
indigenous knowledge and cultural expressions are not eligible for protection under
the “modern” IP system because of the stringent requirements of present IP laws, like
originality, material form, novelty and limited duration. These are major barriers for
the protection of indigenous peoples’ rights in region of Kashmir43.
To start with, copyright protection requires there is the requirement for originality
‘Further, works’ to be fixed in a material form., which in the case of folklore is
difficult to establish because of the regular process of creativity. Likewise, it is not
easy to establish and identify ownership. The duration of protection is also
problematic.
For ‘works’ that date back from ancient times the term of protection have well
expired; however, concerns within indigenous communities suggest that protection
should be without time limits. This chapter also considers the legal protection of

41
There is misappropriation of name of the pashmina by the producers of various countries as Nepal ,
Magnolia, Nepal , China.
42
Supra note 6
43
Kamal Puri, How Intellectual Property Rights Could Work Better For Developing Countries and
Poor People, Transcript, Session 3: Traditional Knowledge and Folklore , The Royal Society 6
Carlton House Terrace, London SW1Y 5AG, 21st – 22nd Feb, 2002(last accessed on 30 Nov, 2011)

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folklore from outside the domain of intellectual property, noting case law that draws
on customary law, legislations concerning cultural heritage .44
Then coming to the Patent regime here also T K can not get the protection of
patent regime as because it does not fulfil the criteria of novelty requirement as it has
been followed by the thousands of the year there is nothing like novel element in it.
More then that community ownership is not reflected under the patent regime while in
case of traditional knowledge where community interest is involved . So patent
regime is also not going to help for protection of TK and TCE in case of pahmina.
Then coming to the regime of the Protection of Plant Variety and Farmer’s right
Here there is nothing like plant or plant variety as here pahmina shawl comes under
the category of handidcrafts . This legislation provides the protection to the rights of
the farmer or breeder . Here in case of pashmina they are neither farmer nor breeder .
So accordingly can not get protection under this regime as well.
GI is also not sufficient to protect the TK as I have mentioned it previous chapter.
Design protection under current international law, not applies to TCEs. No harmony
at the WIPO today yet exists as to the attribution of an IP Right to TCEs which would
empower the indigenous, local communities against appropriation of their work by
mass cultural industries as pashmina is suffering toady.45

Suggestion and conclusion

As I have discussed in previous chapter that current IP regime is not sufficient for
the protection of TK which is expressed in form of pashmina product. So they are left
out in the cold. It cannot get effective protection under the present IP regime as it does
not fufill the requirement which current IP regime requires as I have discussed this
thing in previous chapter. The points which I have kept in my mind in suggesting the
model law are communal ownership, protection from misappropriation, destruction,
development of, practical and cost effective mechanisms for just compensation or
benefit sharing if they in case of they suffer loss due misappropriation So there is a

44
Dwijen Rangnekar, Indigenous Heritage and Intellectual Property: Genetic Resources, Traditional
Knowledge and Folklore, Kluwer Law International (2003),, available at
http://www2.warwick.ac.uk/fac/soc/law/elj/lgd/2004_1/rangnekar/ (last accessed on 1st Dec., 2011)
45
Marion Panizzon, Traditional Knowledge and Geographical Indications: Foundations, Interests and
Negotiating Positions, Swiss National Centre for Competence and Research, Working Paper No.
2005/01,October, 2006

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need development of a robust sui generis (which means of its own kind) system of
legal protection.
Since I P regime is not sufficient to protect the TK so there is need for sue generis
protection . For protecting the traditional knowledge in a effective way three things
to be present there, first is knowledge per se ,second is product of such knowledge
and third is the process by which such a product comes into the existence. So here
protection under the sue generis must akin to the protection given process patent
,product patent and protection of trade secret. There right must be exist without any
time limit . Sue generis protection should give them monopolised rights to include to
enable them exploit the commercial benefit of such knowledge which they acquired
through the thousands of years . The Legislation which is sue generis in nature, which
is respectful of indigenous culture, traditions and which is culturally appropriate. Such
legislation will help the indigenous people to protect their TK which is expressed in
form of the pashmina. So consequently economic and cultural development in the
countries will lead to reduction of poverty in the world. For prevention of bio piracy
the government of India has developed the digital library of traditional knowledge
related to medicinal plant . So same should also be applied in case of traditional
knowledge which is related to folk tales, folk poetry, signs, words, musical
expressions, such as folk songs , instrumental music, weaving, needlework, textiles,
carpets ,pottery, terracotta, mosaic, woodwork, metal ware, jewellery, etc. so that
effective protection to TK and TCE to be granted.

By Kirti Singh
LL.M. Second Year
NLSIU, Banglore

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