RG Anand vs Delux Films Case Explained

R.G Anand vs M/S. Delux Films & Ors
Citation: AIR 1978 SC 1613
Date of Judgment: 18-08-1978

RG Anand vs Delux Films is a well-known legal case in Indian jurisprudence that deals with the copyright infringement of a play. Here’s a case study of R.G. Anand vs Delux Films.

Bare Act PDFs

Case Background

  • RG Anand wrote a play called “Hum Hindustani,” and it was first performed in 1953.
  • He granted exclusive rights to perform the play to a theatre company called Uptown Theaters.
  • The play gained immense popularity, and it was performed in various cities across India.

Infringement by Delux Films

  • Delux Films produced a movie titled “New Delhi” in 1956, which incorporated elements of Anand’s play, including the plot, characters, and dialogues.
  • RG Anand filed a lawsuit against Delux Films, alleging that they had copied significant portions of his play without his permission.

Legal Issues

The primary legal issue, in this case, was whether Delux Films’ movie “New Delhi” constituted copyright infringement by copying elements of RG Anand’s play “Hum Hindustani.”

Related Law Note: 4 Factors That Determine Fair Use Under Copyright Law

Key Legal Principles and Ruling

  • The case is significant because it helped establish the principles of copyright law in India.
  • The courts held that even though the movie was not a verbatim copy of the play, it had copied the essential and distinctive elements of the play, and thus, it constituted copyright infringement.
  • The courts emphasized that copyright extends not just to the exact words or expressions but also to the substance, form, and manner in which the material is presented.


  • The RG Anand vs Delux Films case is a landmark case in Indian copyright law as it highlighted the importance of protecting the underlying ideas and expressions in creative works.
  • The case established the principle that copyright infringement can occur even if there is not an exact word-for-word copy but a substantial similarity in the expression.

This case study serves as a notable example of how courts determine copyright infringement in cases where there is substantial similarity between two works. It underscores the importance of protecting intellectual property rights and the creative expression of authors and playwrights.

Sravani Ravinuthala
WritingLaw » Case Laws » RG Anand vs Delux Films – Copyright Case Explained Law Study Material
If you are a regular reader, please consider buying the Law PDFs and MCQ Tests. You will love them. You may also support us with any amount you like. Thank You.