Delhi High Court Denies Injunction To Golfer Gurbaaz Mann, Finds No Prima Facie Copying In IGPL Event

The Delhi High Court on 10 April, dismissed an application for an interim injunction filed by professional golfer Gurbaaz Pratap Singh Mann, refusing to restrain entities from operating the “IGPL FLASH GOLF” tournament.

Justice Tejas Karia held that while Mann owns a valid copyright in the literary work describing his golf format, he failed to establish a prima facie case of unauthorized copying by the organisers of the Indian Golf Premier League (IGPL).

The Bench held:

“...the Plaintiff has failed to demonstrate a prima facie case of copying concerning the literary work titled “SHOT SQUAD LEAGUE” by the Defendants through their use of the Impugned Sheet for the Impugned Work. Comparative analysis indicates the absence of any unauthorized copying. Since the Defendants have not reproduced the Plaintiff's work in the Impugned Sheet related to the Impugned Work, they cannot be restrained in the manner sought by the Plaintiff.”

The suit arose from an application filed by Mann seeking an interim injunction against alleged copyright infringement, trademark violation, and breach of confidence in relation to his “SHOT SQUAD LEAGUE” format.

Mann claimed that the defendants had launched a deceptively similar tournament by misappropriating his registered literary work under the Copyright Act, 1957, along with his unique team mechanics and specialised player rules.

He contended that Kunwar Bhandari had participated in his 2020 tournament and subsequently conspired with others to launch “IGPL FLASH GOLF” using his proprietary format, asserting prior access to the same.

The defendants, including Bhandari and the IGPL organisers, argued that Mann was attempting to monopolise abstract rules and gameplay ideas, which are not protectable in law.

The Court found that the IGPL format was substantively different from Mann's format. It noted that while Mann's format required players to declare a specialisation, the IGPL format only provided for pre-assignment of shots, which constituted a materially distinct mechanism.

It further held that team-based play is a recognised feature of golf governed by standard rules and cannot be claimed as an original concept. On other aspects such as time-keeping and drop zones, the Court observed that these were either common to the traditional game or implemented differently by the defendants, including a specific 120-second-per-hole limit.

The Bench held that the balance of convenience favoured the defendants, as restraining a public sporting event in the absence of clear evidence of copying would be inequitable.

Accordingly, the Court dismissed the application for interim injunction. However, it directed that the defendants remain bound by their undertaking to use the mark “FLASH” instead of “SMASH” during the pendency of the suit.