The case revolves around a copyright infringement suit filed by Ranjan Vasudeo Kolambe against Appa Hatnure and another respondent, alleging unauthorized copying of Kolambe's original books on Indian Economy and Constitution, which are widely used in Maharashtra for competitive examination preparation. Kolambe sought an interim injunction to stop the sale and distribution of respondents' books, which allegedly imitated his work. The District Court denied the injunction, leading to this appeal.

1. Plaintiff's Allegations (Paras 3–7)

• Claim: Kolambe alleged that the defendants copied content from his two books, “Bhartiya Arthavyavastha” and “Bhartiya Rajyaghatna Prashasan,” which were original works based on years of study and were created for his coaching institute.
• Incident: Plaintiff discovered in 2023 that the defendants published two books, “Class Notes Bhartiya Arthvyavastha” and “Class Notes Rajyaghatna,” which he claims substantially resemble his own works. The plaintiff sought legal recourse, including criminal charges.

2. Defendants' Position (Paras 10–11)

• Defense: Defendants argued that their works were independently created using publicly available sources (e.g., state board books and NCERT textbooks) and were not based on Kolambe’s books.
• Originality Claim: They asserted that their books are educational compilations tailored for competitive exams, emphasizing public domain data and facts rather than original literary expression.
• Legal Precedence: The defendants held valid copyright registrations for their books and contended that copyright infringement could not be established solely based on alleged similarities in general topics.

3. District Court's Findings (Paras 16–18)

• Observations: The District Judge observed that Kolambe’s books and the defendants’ books covered similar topics but were not word-for-word copies.
• Copyright and Public Domain: The Court highlighted that factual information on public topics like Indian Economy and Constitution is not copyright-protected.
• Outcome: The District Court rejected the temporary injunction, reasoning that Kolambe failed to demonstrate a prima facie case of copyright infringement.

4. High Court Analysis and Conclusion (Paras 35–46)

• Standard of Review: The High Court, while affirming the lower court's discretion, referenced the principle that appellate courts do not easily overturn interim injunction decisions unless clear arbitrariness is shown.
• Doctrine of Public Domain: It emphasized that copyright protection cannot be extended to basic, factual information accessible in the public domain, especially in educational materials for exams.

Legal Ratio

1. Public Domain and Copyright: Educational notes on public domain subjects (like Indian Economy and Constitution) are not protected by copyright if they only compile public data without unique, original interpretation or expression.
2. Burden of Proof for Originality: To claim copyright protection, plaintiffs must demonstrate that their work involves creative expression, skill, and judgment beyond merely compiling factual data.
3. Discretion in Injunctions: An appellate court will not disturb a lower court’s refusal to grant an injunction unless the discretion was used arbitrarily or without basis.

Subjects:

Copyright Infringement in Educational Publications

Intellectual Property, Copyright Law, Educational Material, Originality, Public Domain