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    <title>1978 (8) TMI 231 - Supreme Court</title>
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    <description>Copyright protects the expression of a work, including its form, arrangement, incidents and treatment, but not the underlying idea, theme or common subject matter. Applying the tests of substantial taking, colourable imitation and overall impression, the Court compared the film and the play as wholes rather than by isolating individual similarities. It found material differences in plot, characterisation, treatment, climaxes and social themes, and held that the similarities were attributable to the shared idea and were only trivial or incidental. The Court stated that piracy must be proved by clear and cogent evidence, and concluded that the film did not reproduce a substantial and material part of the play.</description>
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      <title>1978 (8) TMI 231 - Supreme Court</title>
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