Delhi High Court Cancels Copyright On Bicycle Parts Label For Lack Of Originality

The Delhi High Court has cancelled the copyright registration of a product packaging label used by one Tara Singh for bicycle parts, holding that the sticker was a substantial imitation of Bombay Metal Works Pvt. Ltd.'s label in its layout, colour scheme and arrangement, despite bearing a different trade name.

“It is trite law that Copyright protection is granted to an artistic work under the Act, only if the said artistic work satisfies the standard of originality,” Justice Tejas Karia said in an order dated March 28, 2026.

Bombay Metal Works (P) Ltd., engaged in manufacturing and marketing bicycle parts including “Ball Head Racer,” had adopted distinctive packaging featuring a sticker in which it holds copyright.

The sticker comprises a yellow circle on a golden background, with black lettering around the circle and a red centre bearing yellow lettering for its “BM” logo.

The company stated that in January 2002 it discovered that Tara Singh, proprietor of R.S. Industries (P) Ltd., was using deceptively similar packaging, prompting it to file a civil suit. The Court had granted interim relief restraining such use. The impugned sticker itself was later discovered in 2004.

According to the petitioner, it came to know in 2006 that the respondent had obtained the impugned copyright registration for a similar sticker and was relying on it to assert proprietary rights. It therefore approached the High Court under Section 50 of the Copyright Act, 1957, seeking rectification of the register.

The petitioner argued that the respondent's sticker was a colourable and slavish imitation of its artistic work, pointing to similarities in the overall colour scheme, roundel placement, and layout. It also alleged that the adoption was mala fide and intended to misappropriate its goodwill.

Opposing the plea, Tara Singh maintained that the two works bore no visual, structural or conceptual resemblance. Stress was laid on the differing titles, 'BM LIMITED' and 'RAJIS QUALITY AND QUANTITY', to argue that the works were clearly distinguishable. He also contended that no monopoly could be claimed over common elements such as the colour yellow. The choice of colours, he said, was driven by function, ensuring clarity and readability.

The Court, however, found that Bombay Metal Works fell within the scope of an “aggrieved person” under Section 50. Both sides operate in the same line of business, and the presence of the impugned sticker on the register, it noted, had the potential to dilute the company's goodwill.

A comparison of the two works led the Court to a different conclusion on similarity. Looking at their overall features rather than isolated elements, it found a clear overlap. Each sticker carried a yellow circular element, with the trade names set out in yellow lettering against a red background. The placement of accompanying text in black lettering followed a similar pattern as well.

“The centre of both the competing stickers consists of a yellow roundel/circle, with Trade Names of the Petitioner and Respondent No.1 'BM' and 'Rajis' respectively mentioned in yellow lettering on a red background. Further, the words 'QUALITY' and 'QUANTITY' mentioned in black lettering on the Impugned Sticker are placed similarly as the name and location of the Plaintiff company on the Petitioner's Sticker,” the court observed.

Holding that the artistic work in challenge lacked originality and amounted to substantial imitation, the Court allowed the petition and directed that the copyright registration be cancelled and expunged from the Register of Copyright.