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"5. Copyright is thus a statutory claim, and the complaint must be established within the strict provisions of the Act. Questions have come up before courts whether an abridgment of an original work would constitute an infringement of copyright; equally, whether such abridged work could upon its own statute, claim the protection of copyright. Questions : have arisen whether there could be copyright in a title to a work; and whether there could fee copyright in a title to a work; and whether there could free copyright in a particular arrangement of a pre-existing non-copyright material, or the pre-existing non-copyright material, or the publication verbatim at speeches delivered by another. Macmillan v. Suresh Chander Deb, ILR 17 Cat 951 is of particular interest, since the point involved was whether the selection and arrangement of non-copyright poems in such a work as Palgrave's "Golden Treasury" could claim protection. The principle was enunciated that protection could 'be claimed, for, as Lord Eldon laid down in Longman v. Winchester, (1809)16 Ves 269 "...... a work consisting of a selection from various authors, two men might perhaps make the same selection; but that must be by resorting to the original authors, not by taking advantage of the selection already made by another."

1900 AC 539 is also of interest, because It related to the publication of verbatim transcripts of the speeches of another; it was held that such a person was an "author" of the report within the meaning of the Copyright Act and entitled to protection. It has been clearly laid down that there is no copyright in a 'title' as such, since this is not substantially enough to merit the claim to protection. It may be capable of protection only in a "passing off" actions; See Dicks v. Yates, (1881) 18 Ch D 79 and other authorities listed in Halsbury (Simonds Edn.) "Vol.8, p.377, 'under paragraph 691. What is of more relevance to the present matter is that an abridgment is not an infringement of copyright, and, in itself, could be a source of copyright. Thus, there could be copyright in notes, even though the matter contained therein might be found. In standard works; see 8 Halsbury page 375, paragraph 6SS; Copinger, pages 53 and 154, Russell-Carks page 23; 46 Mad LJ 637 : (AIR 1924 PC 75). See also Gyles v. Wilcox, (1941)2 Atk. 141."