25 March 2024

A Landmark Decision In Copyright Law – Addala Sitamahalakshmi vs State Of Andhra Pradesh

Accures Legal


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In a recent ruling by Justice V Sujtha of the Andhra Pradesh High Court, a significant legal precedent was set in the case of Addala Sitamahalakshmi versus the State of Andhra Pradesh.
India Intellectual Property
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In a recent ruling by Justice V Sujtha of the Andhra Pradesh High Court, a significant legal precedent was set in the case of Addala Sitamahalakshmi versus the State of Andhra Pradesh. The case revolves around the copyright issues concerning educational textbooks published by Deepthi Publications, particularly focusing on Mathematics, Physics, Chemistry, Botany, and Zoology for intermediate classes.

Case Background:

The petitioner, Addala Sitamahalakshmi, challenged a 2010 Government order that prohibited private colleges from publishing textbooks of the Telugu Akademi. Additionally, Sitamahalakshmi sought the quashing of a criminal case filed against them in 2011 for alleged piracy. The contention was that academic or non-literary books, even if pirated, would be protected under Section 52 of the Copyright Act.

Court Observations and Reasoning:

  1. Scope of Copyright Act: The court emphasized that the Copyright Act pertains to original literary, dramatic, musical, and artistic works.
  2. Nature of Mathematical Equations: It was observed that mathematical questions represent the laws of nature, and the mere discovery of such laws does not grant a monopoly to those who describe them. Language serves as a limited medium for describing these laws.
  3. Protection of Intellectual Concepts: While the Act protects intellectual concepts expressed through literary, musical, graphical, or other artistic forms, mathematical equations and scientific subjects are considered laws of nature and matters of fact. Therefore, individuals are authorized to utilize them without fear of copyright infringement.
  4. Exception for Educational Use: Even if the petitioner's books were deemed pirated copies of other works, such action falls under the exception provided in Section 52, which allows for fair use in educational contexts for the benefit of students and educational institutions.
  5. Subject Matter of Copyright: Section 13 of the Act delineates the subject matter of copyright as "original" literary, dramatic, musical, and artistic works. Since the books in question are non-literary, they do not fall within the ambit of copyright protection.

Court Decision:

In light of these observations, the court ruled that mathematical equations and scientific subjects are laws of nature, accessible to all without the constraints of copyright infringement. Consequently, the criminal proceedings against Addala Sitamahalakshmi were quashed. The court also directed government authorities to refrain from interfering in the legitimate business operations of the petitioner under the guise of governmental orders.


The verdict in Addala Sitamahalakshmi versus the State of Andhra Pradesh marks a significant development in copyright law, particularly concerning educational materials. By recognizing the distinction between original literary works and factual information such as mathematical equations, the court has provided clarity on the scope of copyright protection in the academic domain. This decision underscores the importance of balancing intellectual property rights with the broader public interest in access to knowledge and education.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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