R.G Anand vs M/S. Delux Films & Ors on 18 August, 1978
12. No doubt the central theme of the articles published by the second plaintiff and that of the drama and movie is the same, though the emphasis in the drama and the movie is more on human bondage, particularly of Indian women. The articles published by Ashiwini Sarin also contain an autobiographical account of the part actually played by him in the affair. He has presented the whole affair in his own style. But that at the most would give the plaintiffs copyright in respect of these articles. There cannot, however, be a copyright in an event which has actually taken place. There is a distinction between the materials upon which one claiming copyright has worked and the product of the application of his skill, judgment, labour and literary talent to these materials. Ideas, information, natural phenomena and events on which an author expends his skill, labour, capital, judgment and literary talent are common property and are not the subject of copyright. As held by the Supreme Court in R. G Anand v. Delux Films . "There can be no copywriting in an idea, subject matter, themes, plots or historical or legendary facts and violation of the copyright in such cases is confined to the form, manner, arrangement and expression of the idea by the author of the author of the copyrighted work." The form, manner or arrangement of a drama and movie are materially different from a newspaper article and by very nature of the media there is fundamental and substantial dissimilarity the mode of expression of the idea in a newspaper article and in a stage play or in a movie. Prima facie, therefore, the claim in respect of infringement of copyright appears to be misconceived.