SUPER CASSETTE INDUSTRIES LTD.

VS ENTERTAINMENT NETWORK(INDIA)

AIR 2004 Delhi 326, 112 (2004) DLT 549

Submitted by:

Radhika Prasad

B.A., LL.B.(Hons.)

Roll no. – 2139

2019-2024

Eighth Semester

Submitted to:

Dr. S.C.Roy

Professor Of Law

March , 2023

Chanakya National Law University, Patna

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 DECLARATION BY THE CANDIDATE

I, RADHIKA PRASAD, student of Chanakya National Law University, hereby declare that
the project work submitted to Chanakya National Law University, Patna is a record of an
original work done by me under the guidance of Dr. S.C.Roy , teacher in subject, Chanakya
National Law University, Patna and has not been submitted for any other degree or diploma.

NAME: RADHIKA PRASAD

ROLL NO: 2139

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 ACKNOWLEDGEMENT

I have taken efforts in this project. However, it would not have been possible without the kind
support and help of many individuals. I would like to extend my thanks to all those who have
helped me some way or the other in this project.

First of all, I would like to thank the almighty god that he has kept me in good health during
the framing and making of this project. I would also like to thank my professor-Dr. S.C.Roy
who have given me the opportunity to do the research work on this topic. I would like to
thank all those unseen hands who supported me while making the project.

THANK YOU,

RADHIKA PRASAD

ROLL NO. - 2139

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 CONTENTS

1)INTRODUCTION...................................................................................5

-STATEMENT OF FACT.......................................................................5

-ISSUES FRAMED..................................................................................6

-LEGAL PROVISIONS ON THE ISSUES..............................................6

2)ARGUMENTS PROS AND CONS.........................................................7

3)RELEVANT CASES CITED AND DISCUSSED..................................10

4)JUDGEMENT OF THE COURT.............................................................13

5)ANALYSIS OF THE JUDGEMENT.......................................................14

6)CONCLUSION..........................................................................................17

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 INTRODUCTION

STATEMENT OF FACTS

This appeal in this case 1is directed against the order dated 20th October, 2003 passed by the
Copyright Board at New Delhi in Case No. 10/2003. Appellant's main grievance is against
the direction of the Copyright Board directing the Registrar of Copyrights to grant a
compulsory license under Section 31(1)(b) of the Copyrights Act, 1957.
The appellant is one of the leading music companies engaged in the production and/or
acquisition of rights in sound recordings. According as regards the appellant is concerned,
through keen perception of ever changing consumer practices, infrastructural investment,
technological upgradations and a skilled, cohesive work force, and an aggressive
commitment towards quality, companies such as the appellant play a vital role in creating the
music which then become available for the mass consumption.The appellant’s most valuable
asset is the copyrights in cinematographic films and sound recordings. The music of the
appellant is either produced by the appellant at its own studios, or is acquired by way of
assignments.
The respondent which broadcasts under the brand name "Radio Mirchi" is admittedly a
leading FM radio broadcaster which has nationwide listenership. This broadcaster launched
its Mumbai Station only in May, 2002 and its Delhi Station only in April, 2003. Accordingly,
this phenomenon has in a very short time not only revolutionalized the radio industry but had
a significant impact on the music industry in general, and producers and owners of copyright
in sound recordings in particular.
The respondent was regularly airing songs/sound recordings belonging to the repertoire of the
appellant on its FM Radio Station. The respondent has not obtained any authorization or
license to communicate songs/sound recordings of the appellant to the public either by means
of radio or in any other manner whatsoever. It is also seen that the appellant gave several
notices to the respondent asking it to desist immediately and when the respondent did not pay
any attention to the notices sent by the appellant then the appellant filed a suit for damages
for copyright infringement and sought a permanent injunction against respondent on 6.6.2002
in Suit No. 1069/2002. Therein, Copyright board has given direction to grant compulsory
license to the respondent against which the appellant has appealed.

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AIR 2004 Delhi 326

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ISSUES FRAMED

1)Whether an infringer is entitled to be considered for the grant of compulsory licenses under
Section 31 of the Act without stopping the illegal broadcast of sound recording of the
appellant?

2)Whether principles of natural justice are applicable to quasi judicial bodies?

3)Under Section 31 of the Copyright Act,1957 every complainant has to be granted license or
license can be refused on valid grounds?

4)While interpreting the statute gap, if any, can be filled by international conventions (Rome
and Berne) to which India is a party?

5)When once the copyright is taken in the public domain then it becomes a commercial right
and refusal to grant license has to be on reasonable grounds?

LEGAL PROVISIONS ON THE ISSUES

Section 31 of Copyright Act, 1957.

Section 14 of Copyrights Act,1957.

Section 51 of Copyrights Act,1957.

Section 52 of Copyright Act, 1957.

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 ARGUMENTS PROS AND CONS

ARGUMENTS ON BEHALF OF THE APPELLANT

1)The Appellant alleged that the appellant has invested several crores of rupees in acquiring
and developing technology and infrastructure, as well as recruiting musical talent, in order to
produce sound recordings. They also spend significant amount of money in acquiring rights
to sound recordings by assignment. They are, therefore, an indispensable part of the process
whereby music reaches consumers. The primary asset of the appellant's music division is its
copyright in sound recordings, and its only source of revenue is from the sales of sound
recordings in which it owns the copyright, in the form of audio cassettes and CDs. In the
absence of such revenue, the music business of the appellant would be wholly unviable, and
music would not be produced in the first place.

2)It is averred by the appellant that it commissioned a survey by IMRB International, an

independent and reputed market research firm, and one of the leading sources for information
on the FM radio industry, of the music consumption habits in Delhi and Mumbai after the
advent of private FM radio stations. The survey concludes that the average number of
cassettes bought in Mumbai post-FM radio, which had been operating in the city for more
than a year at the time the survey was conducted, as well as the amount spent on such
purchases, is reduced by more than 30% as compared to pre-FM radio. The same trend was
observed for CDs as well.

3)The appellant also mentions that sales of audio cassettes and CDs of the latest Indian
movies are maximum from three months before to six months following the release of the
film. The songs of the said movies are exploited by FM radio stations during the crucial
window, little or no interest in or demand for, such music remains, particularly when FM
plays round the clock music. This has a serious adverse impact on the sale of audio cassettes
and CDs of such music cassettes.

4)The appellant filed an application for producing witnesses on 22/23.7.2003 before the
scheduled hearing on July 25, 2003 but the Board turned down the request of the appellant

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for inspection and producing the witnesses. According to the Board, it also rejected the
proposal of counsel for the appellant to present oral testimony of just two witnesses.

5)The Copyright Board has failed to appreciate that the respondent has in any manner made
out or even indicated how the grant of compulsory license to it would be in the interest of the
public at large.

6)It is alleged by the appellant that the infringer of the copyright cannot be allowed to take
advantage of its own wrongs by asking for a compulsory license when a suit for infringement
is pending.

7)The appellant also submitted that Section 31 is an exception to the provisions of Copyright
Act and like all exceptions, it is to be read with care and circumspection.

8)Mr. Kapil Sibal, learned Senior Advocate appearing for the appellant submitted that quasi
judicial bodies also have to adhere to the basic principles of natural justice. He also submitted
that while considering an application for a compulsory license under Section 31 of the
Copyright Act,1957 the Copyright Board acts in a quasi judicial capacity and must act in
accordance with the principles of natural justice.

9)Mr Sibal submitted that the Copyright Board ought to have taken into consideration that
while keeping the public interest in view the appellant itself had given licenses to other
broadcasting agencies such as AIR and Radio City. He also submitted that admittedly the
respondent without obtaining any license or permission started broadcasting music of the
appellant. In other words, the respondent is guilty of infringing the copyright and only when a
notice was sent by the appellant and he was caught that the respondent thought of getting the
license/permission on his own terms.

ARGUMENTS ON BEHALF OF THE RESPONDENT

1)Mr. Dave,on behalf of the respondent submitted that the impugned judgment/order serves
the public interest and order has been passed in consonance with the principles of natural
justice. He submitted that once the music is in the public domain, then public at large has a

8
right to listen to the music. He submitted that it would not be appropriate to allow some
broadcasters to play that music and deny the same privilege to others.

2)Mr. Dave also submitted that the Board had taken relevant factors into consideration and
ignored irrelevant factors while passing the impugned order. He submitted that the
complainant runs the well known FM channel under the brand "Radio Mirchi". The
complainant is the successful bidder for running FM stations in various cities in India and
also has licenses for other cities. The complainant in order to be able to play the songs and
works for which Phonographic Performance Limited (PPL) holds the rights, the complainant
had earlier filed a complaint before the Board and the same was decided on 19.11.2002.
Super Cassettes Limited is not a member of PPL. The complainant made several attempts to
obtain license from Super Cassettes Limited for its works. As per the website of Super
Cassettes Limited, it owns approximately 18,000 titles in its repertoire. Thus,the works which
are in the control of Super Cassettes Ltd are substantial and are essential for running a radio
channel. The complainant wrote letters and has also orally notified Super Cassettes Ltd its
intention to have a license for its works. However, despite repeated assurances orally and in
writing Super Cassettes Ltd has refused to issue a license under one pretext or the other.

3)Mr. Dave relied on a letter sent by the appellant on 21.5.2003 to demonstrate that no
request for adducing evidence was in contemplation. He referred to a letter received from the
Deputy Registrar of Copyrights dated 14.5.2003 in which a direction was given to the
appellant and the respondent to appear on 16.6.2003 and in the fixed proforma it is also
mentioned that the appellant was given liberty to adduce evidence in support of its case.

4)Mr. Salve, also appearing for the respondents submitted that once any artistic work or
music is in public domain then the copyright owner cannot adopt a discriminatory policy to
give license to one and deny to the other. All those who are willing to abide by the terms and
conditions and are prepared to pay the reasonable compensation as decided by the Board,
would be entitled to compulsory license under Section 31 of the Act. Any discrimination
would attract the provisions of M.R.T.P.Act.

5)Mr. Salve also said that Mr. Salve submitted that the submission of the appellant is
misconceived that the appellant was denied opportunity to adduce evidence and consequently
led to violation of the principles of natural justice.

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 RELEVANT CASES CITED AND DISCUSSED

1)British Sky Broadcasting Ltd and Another v. The Performing Right Society Ltd 2
Particularly Reliance is on para 1.4 which is reproduced as under: Given these stakes,it is not
surprising that the issue has been hotly contested. We heard oral evidence from 18 witnesses,
and we have read and taken account of evidence in the form of witness statements and
affidavits from many more. We found all the witnesses to be honest and fair, doing their best
to assist the Tribunal to arrive at a decision. This judgment has been relied primarily for the
purpose that in a case of similar nature evidence was recorded.

2)Medical Education and Registration of the United Kingdom v. Spackman 3 -"On the
hearing of a petition for divorce S., a registered medical practitioner, was found to have
committed adultery with a married woman. The General Medical Council, at a meeting at
which the erasure of his name from the medical register was considered, found that he stood
in a professional relationship to the married woman at all material times and adjudged him to
have been guilty of infamous conduct in a professional respect. In accordance with the
council's standing orders, S. was invited "to state his case and produce the evidence in
support of it". S. sought to negative the court's finding of adultery by tendering evidence,
which though available, was not called in the divorce proceedings. The council refused to
hear fresh evidence on the subject, and directed the erasure of S's name from the register. S.
contended that by reason of the council's refusal to hear the evidence, the due inquiry
required by the Medical Act,1858, s.29 had not been held and there had been a failure of
natural justice." It was held that the refusal to hear the fresh evidence prevented there being
the due inquiry required by the Medical Act,1858, s.29, and an order of certiorari should be
granted."

3)Union of India vs. T. R. Varma 4 - The law requires that such Tribunals should observe
rules of natural justice in the conduct of the enquiry, and if they do so, their decision is not
liable to be impeached on the ground that the procedure followed was not in accordance with
that, which obtains in a Court of Law. Stating it broadly and without intending it to be
exhaustive, it may be observed that rules of natural justice require that a party should have

2
(1998) R.P.C. 467)
3
1943 2 A.E.R 337
4
1957 S.C.R 499

10
the opportunity of adducing all relevant evidence on which he relies, that the evidence of the
opponent should be taken in his presence, and that he should be given the opportunity of
cross-examining the witnesses examined by that party, and that no materials should be relied
on against him without his being given an opportunity of explaining them. If these rules are
satisfied, the enquiry is not open to attack on the ground that the procedure laid down in the
Evidence Act was not strictly followed.

4)Raghunath Thakur v. State of Bihar 5-But it is an implied principle of the rule of law that
any order having civil consequence should be passed only after following the principles of
natural justice. It has to be realised that blacklisting any person in respect of business
ventures has civil consequence for the future business of the person concerned in any event.
Even if the rules do not express so, it is an elementary principle of natural justice that parties
affected by any order should have right of being heard.

5)K.L. Tripathy v. State Bank of India 6, the Apex Court observed that the basic
requirement is that there must be a fair play in action and decision must be arrived at in a just
and objective manner with regard to the relevance of the materials and reasons. The rules of
natural justice are flexible and cannot be put in a rigid formula.

6)The Chief Controlling Revenue Authority, Bombay vs. Maharashtra Sugar Mills
Ltd7 .- Particularly stress is laid on para on 13 of the judgment in which it is mentioned that
when an authority has discretion to decide a case in a particular manner, then that discretion
invested by the legislature cannot be taken away.

7)Visakha & Others vs. State of Rajasthan & Others 8 and submitted that where the
domestic laws are silent then that gap can be filled by the international conventions. Mr.
Salve submitted that once the copyright is taken in public domain, then it becomes
commercial right and refusal to give license has to be on reasonable grounds.

5
1980 AIR 620
6
AIR 1984 SC 274
7
AIR 35 1948 Bom. 254
8
AIR 1997 SC 3011

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8)Phonographic Performance Limited vs. Retail Broadcast Services Ltd 9. - In this case
the plaintiff, PPL sued the defendant, who operated a radio broadcast service for
infringement. The court observed as under:- " ... I have considerable doubts as to whether the
continuance of this litigation is a worthwhile exercise. I was told that the defendant is likely
to have a third try to send a section 135B(1) notice. It is likely to get this right. The Copyright
Tribunal will shortly be seized of a reference. That will be resolved by consent or a decision,
either of which will set terms for the future. As regards damages up until that point, it is not
easy to see how they could be different from the rate set by the Tribunal...."

9)Apparel Export Promotion Council vs. A.K.Chopra 10 reported as . The court observed:-
" These international instruments cast an obligation on the Indian State to gender sensitize its
laws and the Courts are under an obligation to see that the message of the international
instruments is not allowed to be drowned.... The Courts are under an obligation to give due
regard to international conventions and norms for construing domestic laws, more so, when
there is no inconsistency between them and there is a void in domestic law. "

10)Australian case, Fair Fitness Music Association vs. Australian Performing Right
Association Ltd11. In this case the license scheme was challenged by a Fitness Group, which
used music of the Australian Performing Right Association. The Copyright Tribunal
discussed the going rate and relied on the decision of House of Lords in General Tyre and
Rubber Co. vs. Firestone Tyre and Rubber Co. 1976 RPC 197 and held that appropriate
damages may be ascertained by looking at what the infringer would have had to pay, if
instead of infringing, he had come to the licensed for the same purpose.

9
1995 FSR 813
10
AIR 1999 SC 274
11
43 IPR 667

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 JUDGEMENT BY THE COURT

This appeal was directed against the order dated 20th October, 2003 passed by the Copyright
Board at New Delhi in Case No. 10/2003. Appellant's main grievance was against the
direction of the Copyright Board directing the Registrar of Copyrights to grant a compulsory
license under Section 31(1)(b) of the Copyrights Act, 1957

On consideration of the totality of facts and circumstances the impugned order, granting
compulsory license to the respondent had to be set aside. It was ordered accordingly.
Consequently the respondent is restrained from infringing the copyright of the appellant.

The respondent is directed to give an undertaking to this Court within one week that
songs/sound recording belonging to the repertoire of the appellant would not be played by the
respondent.

This case was remitted back to the Copyright Board directing the Board to reconsider the
application of the respondent for grant of compulsory license under Section 31 of the Act
after giving adequate opportunity to the parties to adduce evidence. Of course, the parties
have to adduce evidence within the time frame fixed by the Board.

In view of the facts and circumstances of this case, the Board is directed to decide the
application of the respondent for grant of compulsory license u/s. 31 of the Act by a reasoned
order as expeditiously as possible and in any event within three months. The parties are
directed to appear before the concerned Copyright Board on 12.7.200412.

This court also said that- Before the court part with this case, the court would like to place on
record our appreciation for very able assistance provided to us by the learned counsel
appearing for the parties.In the facts and circumstances of this case, this appeal is allowed in
terms indicated above with costs. The applications and the caveat are also accordingly

disposed of13.

12
Compulsory Licensing in Copyright, LEGAL SERVICE INDIA , https://legalserviceindia.com/legal/article-6626-
compulsory-licensing-in-copyright.html( last accessed Mar 5, 5:00 pm)
13
Ibid.

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 ANALYSIS OF THE JUDGEMENT

ISSUE 1-Whether an infringer is entitled to be considered for the grant of compulsory

licenses under Section 31 of the Act without stopping the illegal broadcast of sound recording
of the appellant?
The Court elaborated the main issue which arises for adjudication in this appeal. Admittedly,
the respondent was regularly airing songs/sound recording belonging to the repertoire of the
appellant on FM Radio Station without permission. The respondent has not obtained any
authorisation, license to communicate songs/sound recordings to the public from the
appellant. The respondent did not desist despite sending several notices and continued to air
songs and sound recording belonging to the repertoire of the appellant with impunity.
Admittedly, the respondent is a rank infringer. If rank infringers like the respondent have to
be granted compulsory licenses under Section 31 of the Act, then it would really be putting
premium on their defaults. This would also encourage others to first infringe and when the
infringement is discovered then apply for a compulsory license. That can never be the
intention of the legislature. In the court’s opinion, one who does not have any respect for law
is really not entitled to be considered for grant of license under Section 31 of the Copyright
Act. At the same time Court would not like to take a very harsh view of barring a ticketless
traveller from boarding the train for ever. But at the same time court is clearly of the opinion
that until the respondent completely stops illegal broadcasting of songs and sound recording
belonging to the repertoire of the appellant, its (respondent's) application for compulsory
license shall not to be considered. It is really for the Copyright Board to impose restrictions
and conditions according to facts and circumstances of each case.

ISSUE 2-Whether principles of natural justice are applicable to quasi judicial bodies?-
In the instant case the appellant had filed an application for producing witnesses. It is also an
admitted position that the entire evidence of the appellant was available before the hearing of
this case was concluded. Even then the appellant's request to produce evidence was rejected.
This is also not the case in which the appellant has failed to produce evidence despite many
opportunities. In case the Board was of the opinion that there has been delay in filing
application, then they would be justified in imposing costs or other terms. But to deny the
appellant an opportunity to adduce evidence, when all the witnesses were present before
conclusion of the hearing was not justified. In a large number of cases the Courts consistently

14
and repeatedly have held that even an administrative order which involves civil
consequences, must be made in consonance with the rules of natural justice. To deny
opportunity to a party to lead evidence particularly when the witnesses were present at the
hearing constitutes violation of principles of natural justice. According to the settled position
of law, principles of natural justice are fully applicable to quasi judicial bodies.

ISSUE 3-Under Section 31 of the Copyright Act,1957 every complainant has to be granted
license or license can be refused on valid grounds?
Court has carefully analysed Section 31 of the Copyright Act 1957. According to the
language of the section question of compulsory license would arise only when the artistic
work or music has been withheld from the public. In the instant case, admittedly licenses
have already been granted to other broadcasters like AIR and Radio City, who have
substantial presence, in that event, whether the appellant can be compelled to grant
compulsory license to others, would really be decided on the facts and circumstances of each
case. When the licenses have already been granted to other broadcasters, who have
substantial presence, then perhaps the application for grant of compulsory license will be
treated differently, than in a situation where the artistic work has been totally withheld from
the public. The legislature in its wisdom has used the expression "may" in Section 31(1).
According to Section 31 it is not imperative for the Board to grant license to each and every
complainant. In our considered view the license can be granted or denied on valid grounds.
Section 31 itself envisages that the decision to grant or refuse a license should be made after
holding such inquiry as it may deem necessary. While granting compulsory licenses the
Board must take into consideration whether the work has been totally withheld from public or
licenses have been granted to other broadcasters and to what extent public interest is served.
In the instant case licenses were granted to other broadcasting agencies such as AIR and
Radio City. The Board ought to have taken into consideration this vital factor while arriving
at a decision to grant compulsory license to the respondent.
On a careful consideration of this Section, it is abundantly clear that the Board did not take
into consideration this vital and important factor that the appellant had already granted
licenses to other broadcasting agencies,namely, AIR and Radio City. The Board infact ought
to have considered the impact of two licenses already granted by the appellant as far as public
interest is concerned. In the Court’s opinion, no merit was found in the submission of Mr.
Dave that compulsory licenses have to be granted to all those who have applied and are
prepared to pay the license fee and there is no discretion left with the Board. This

15
interpretation is clearly against the spirit of Section 31 of the Copyright Act. In case
compulsory licenses have to be granted to all, then there was no need of any inquiry as
envisaged by this Section. Apart from that the legislature in its wisdom has incorporated
expression `may' and not `shall'. That is also indicative of the fact that the Board has been
given discretion. According to the language of this Section, the case for grant of compulsory
license can be considered only after the Board gives reasonable opportunity of being heard to
the owner and after holding such inquiry is satisfied that the grounds for such refusal are not
reasonable, then only the question of the grant of compulsory license is considered. Further
according to Section 31(2) of the Act it is abundantly clear that when two more persons have
made a complaint under sub section 1(1), the licenses shall be granted to the complainant,
who in the opinion of the Copyright Board would best serve the interest of the general public.
A plain reading of this language clearly reveals that while granting licenses the Board has a
discretion to grant or to refuse licenses on valid grounds.

ISSUE 4-While interpreting the statute gap, if any, can be filled by international conventions
(Rome and Berne) to which India is a party?.- It is well settled that while interpreting the
statute, these conventions have great relevance particularly when specific provisions are
silent. In Visakha's case it has been observed by their Lordships of the Apex Court that when
the specific provisions of law are silent then, that gap can be filled by these international
conventions.

ISSUE 5-Once the copyright is taken in the public domain then it becomes a commercial
right and refusal to grant license has to be on reasonable grounds?- Court has carefully
considered this aspect and we are in agreement with the respondent that once a copyright is
taken in public domain then it becomes commercial right and refusal to grant license has to
be on reasonable grounds. The reply to this proposition is inherent in the language of 31 of
the Act. It is clearly incorporated in the language of this Section that the case of the
complainant for grant of compulsory license can be considered if the work has been withheld
from public and after giving reasonable opportunity to the owner of the copyright holds
inquiry and comes to the conclusion that grounds of refusal are not reasonable. Once the
copyright is in the public domain, refusal has to be on reasonable and valid grounds14.

14
Supra 12.

16
 CONCLUSION

Thus, Compliance of Section 31 of the Copyrights act is of utmost importance. While making
an order under Section 31(1) of the Act the Board has to maintain a delicate balance between
private rights of the copyright vis a vis public interest.The Copyright Board must take into
consideration the following parameters while deciding application for compulsory license: (i)
The work in question should have been published or performed in public; (ii) The owner of
the copyright/sound recordings should have refused to republish or allowed republication or
the performance in public of the work by the reasons of which the work is with the public;
(iii) Has refused to allow communication by a broadcaster of such work on terms which the
board must consider reasonable.
The most important task of the Board is to maintain balance between compensation
demanded and compensation to be paid by the complainant. For deciding this objectively,
proper opportunities to the parties for adducing leading documentary/oral evidence is
imperative.The Copyright Board in consonance with the principles of natural justice must
give full opportunities to the parties including opportunity of filing pleadings, documents and
adducing oral evidence. The other side may also be given an opportunity of cross-
examination of witnesses
The Board must also take into consideration, whether the licenses have already been granted
to the other broadcasters? Whether by the grant of these licenses, public interest has been
fully served? If the public interest has not been served, then the board would be justified in
granting further compulsory licenses to the complainant.The Board while adjudicating the
application for compulsory license must also determine that the parties before the Board have
their competing commercial interest. The public interest can only be safeguarded by the
Board. This indeed is the main duty and obligation of the Board. Any decision which is taken
by the Board must be taken while keeping larger public interest in view.
The Board has to carefully maintain balance between creation of monopoly which is
generally considered opposed to public interest and protecting intellectual property rights as a
measure to encourage creativity in the respective fields.The Board must also take into
consideration, whether the appellant is really the owner of the trademark or the rights of the
owner have been purchased by the sound recording body or by the organiser.The Board must
also take into consideration that once the copyright is taken in public domain, then it becomes
a commercial right and refusal of license has to be on reasonable grounds.

17
 BIBLIOGRAPHY

BOOKS

V.K. Ahuja,Law Relating to Intellectual Property Rights( 3rd Edn., 2022).

Anil Kumar H S and B. Ramakrishna, Fundamentals of Intellectual Property Rights: For

Students, Industrialist and Patent Lawyers(2017).

WEBSITES REFERRED

https://indiankanoon.org/doc/1885590/
https://www.hg.org/legal-articles/supreme-court-allows-appeal-of-entertainment-network-
india-ltd-radio-mirchi-and-refers-matter-back-to-copyright-board-for-compulsory-license-
5506
https://iprlawindia.org/casesummary-super-cassettes-industries-pvt-ltd-vs-music-broadcast-
limited/

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