Factual match information cannot be monopolised through hot news, unfair competition, or unjust enrichment claims.

Delhi HC held that match information and contemporaneous score updates are facts, not copyright subject matter, and Section 16 of the Copyright Act bars any wider common law claim to exclusivity outside the statutory scheme. The plaintiffs could not convert factual sports information into a proprietary right through the hot news doctrine, unfair competition, or unjust enrichment. The Court further held that foreign hot news principles could not be imported to create copyright-like protection, unfair competition could not restrain publication of facts, and the unjust enrichment claim did not justify interim injunctive relief on the pleaded case. The interim injunction was therefore unsustainable.

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Issues: (i) Whether Section 16 of the Copyright Act, 1957 precluded the plaintiffs from claiming exclusivity over match information and contemporaneous score updates; (ii) Whether the plaintiffs were entitled to an interim injunction on the basis of the hot news doctrine, unfair competition, or unjust enrichment.

Issue (i): Whether Section 16 of the Copyright Act, 1957 precluded the plaintiffs from claiming exclusivity over match information and contemporaneous score updates.

Analysis: The claimed protection was not for copyright in a work, but for underlying facts and match information. Section 16 bars copyright or similar rights except under the Act, and the statutory scheme in Chapter VIII separately protects broadcasting and related rights. The Court held that facts and information are not protected as copyright subject matter and that the plaintiffs could not use common law to create a wider proprietary claim over information that the Act does not recognize. The exhaustion of the statutory scheme also meant that no additional exclusive right over match facts could be asserted outside the Act.

Conclusion: The claim was precluded by Section 16 and the connected statutory framework, against the plaintiffs.

Issue (ii): Whether the plaintiffs were entitled to an interim injunction on the basis of the hot news doctrine, unfair competition, or unjust enrichment.

Analysis: The Court held that the hot news doctrine, as developed in foreign authorities, could not be imported to create a new proprietary right in match information in the face of the Copyright Act. It further held that unfair competition could not be used to restrain the publication of facts, because that would amount to judicial creation of copyright-like protection over information. The unjust enrichment claim also failed because the alleged benefit to the defendants was not shown to be at the plaintiffs' expense and, in any event, the pleaded claim was in substance a restitutionary or misappropriation claim that could not support injunctive relief on the facts.

Conclusion: The plaintiffs were not entitled to interim injunction on any of those grounds, against the plaintiffs.

Final Conclusion: The impugned interim injunction was unsustainable in law because match information could not be converted into an exclusive proprietary right through the doctrines of hot news, unfair competition, or unjust enrichment, and the statutory copyright scheme did not permit such protection.

Ratio Decidendi: In the absence of a statutory right, courts cannot create a proprietary monopoly over factual match information or grant injunctive relief against its publication by invoking hot news, unfair competition, or unjust enrichment where the Copyright Act excludes such protection.

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