Bombay High Court

Fortune Films International v Dev Anand

AIR 1979 Bom 1719791 min read
The case in brief30-second read
Facts
Dev Anand acted in a film produced by Fortune Films. A dispute arose over rights in the film and his performance.
Issue
Whether an actor has a separate copyright in his performance in a cinematograph film.
Held
Under the Copyright Act 1957 as it then stood, an actor's performance was not a 'work', so Dev Anand had no separate copyright in it.
Principle
Before the 1994 amendment, Indian law gave performers no copyright in their performances; performers' rights were added later.

Facts

  • Dev Anand acted in a film produced by Fortune Films. A dispute arose over rights in the film and his performance.

Issue

  1. Whether an actor has a separate copyright in his performance in a cinematograph film.

Held

  • Under the Copyright Act 1957 as it then stood, an actor's performance was not a 'work', so Dev Anand had no separate copyright in it.

Cite this

Citation

Fortune Films International v Dev Anand AIR 1979 Bom 17

Reported: https://indiankanoon.org/doc/1686803/. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.