Case Note & Summary
The plaintiffs, Narendra Mohan Singh (proprietor of Sanjay Singh Films) and Manish Jha, filed a suit seeking an injunction against the release of the film 'Manjhi – The Mountain Man', directed by Ketan Mehta and produced by Maya Movies Private Limited, Viacom 18 Motion Pictures, and National Film Development Corporation. The plaintiffs claimed that the second plaintiff had written a script on the life of Dashrath Manjhi, which was shared with the third defendant, Mahendra Jakhar, in confidence. They alleged that the film infringed their copyright and breached confidence. The court examined the plaintiffs' script and the film, finding no substantial similarity. The court noted that the plaintiffs' script was a basic outline, while the film's script was detailed and independently developed. The balance of convenience favored the defendants, as the film was set for release the next day and an injunction would cause significant harm. The court dismissed the notice of motion, allowing the film's release.
Headnote
A) Copyright Law - Infringement of Script - Prima Facie Case - The court considered whether the plaintiffs' script was substantially similar to the final film to warrant an injunction. Held that a comparison of the plaintiffs' script and the film did not reveal substantial similarity, and the plaintiffs failed to establish a prima facie case of copyright infringement (Paras 1-10). B) Breach of Confidence - Confidential Information - Prima Facie Case - The plaintiffs alleged that they shared a basic screenplay with the third defendant in confidence. The court found that the plaintiffs did not sufficiently demonstrate that the information was confidential or that there was a breach, as the film's script was independently developed (Paras 11-15). C) Injunction - Balance of Convenience - Film Release - The court weighed the balance of convenience, noting that the film was scheduled for release the next day and that an injunction would cause irreparable harm to the defendants. Held that the balance of convenience was in favor of the defendants, and no injunction was granted (Paras 16-20).
Issue of Consideration
Whether the plaintiffs have made out a prima facie case for an injunction restraining the release of the film 'Manjhi – The Mountain Man' on grounds of copyright infringement and breach of confidence.
Final Decision
Notice of Motion dismissed. No injunction granted against the release of the film 'Manjhi – The Mountain Man'.
Law Points
- Copyright infringement
- breach of confidence
- prima facie case
- balance of convenience
- substantial similarity
- idea-expression dichotomy
- screenplay copyright
- film release injunction
