Reverse Engineering Faces A Higher Bar In Industries With Defined Standards

C.S No.602 of 2007 – Madras High Court – Date of Decision 3rd September 2025

Background

The note discusses final decision of a case, post-trial, brought by Tractors and Farm Equipment Limited (TAFE), Chennai at the Madras High Court against Standard Corporation India Limited (SCIL), Punjab. TAFE alleged copyright infringement and passing off regarding artistic drawings for its tractor model MF 245 DI and related parts. It was alleged that SCIL's Standard 348 tractor model either copied TAFE's design or was reverse engineered from TAFE's technical drawings.

Issues Framed

The Court considered 15 issues, including:

1. Whether passing off can be claimed under the Copyright Act.
2. Whether the defendant's tractor was a slavish imitation.
3. Whether copyright in the TAFE's drawings was infringed.
4. Whether the TAFE was entitled to damages and other remedies.

Both parties examined two witnesses each. TAFE exhibited a total of 85 documents as evidence, marked as P1 to P85. These included authorization letters, photographs comparing tractor parts, engineering drawings, inspection reports, and other supporting documents.

TAFE's Arguments

1. The drawings qualify as artistic works under the Copyright Act, not as designs under the Designs Act.
2. The drawings were created by TAFE employees, with engineering inputs, and were confidential.
3. SCIL's tractor parts were alleged to be copied or reverse-engineered from TAFE's drawings.

SCIL's Arguments

1. As per Section 15 of the Copyright Act, copyright in designs ceases after 50 reproductions if not registered under the Designs Act.
2. The drawings were not original, as they were based on Massey Ferguson's designs.
3. The tractor parts alleged to be similar were commonly available and manufactured to prescribed standards.
4. No case for copying or passing off was made out.

Court's Analysis & Findings

1. Copyright vs. Design Protection
   1. The Court clarified that Section 15 of the Copyright Act applies only to designs capable of registration under the Designs Act.
   2. The TAFE's industrial drawings were found to be artistic works under the Copyright Act, not designs under the Designs Act, therefore, Section 15(2) did not bar the suit.
2. Originality & Authorship
   1. The Court found that the TAFE's drawings, though based on Massey Ferguson's, had sufficient engineering inputs and modifications to be considered original and authored by TAFE.
3. Copying & Infringement
   1. The TAFE failed to prove that the SCIL had access to its confidential drawings.
   2. Comparative analysis of tractor parts showed minor differences in dimensions; some similarities existed, but many parts were manufactured to industry standards with limited tolerance ranges (e.g., Bureau of Indian Standards, ISO specifications).
   3. The court observed similarities in parts could be due to these standards, not necessarily copying or reverse engineering. Minor differences in dimensions were found in the inspection reports, further weakening the TAFE's claim.
   4. TAFE argued that the SCIL must have reverse-engineered its tractor parts using the TAFE's confidential drawings. However, the court found no evidence that the SCIL had access to the TAFE's drawings. The court noted that drawings were confidential and not available to outsiders, and there was no proof that the SCIL obtained them through employees, dealers, or distributors.
   5. During cross-examination, the SCIL's witness denied reverse engineering and claimed that their company made its own drawings for the Standard 348 model.
   6. TAFE did not produce direct evidence showing that the SCIL copied or reverse-engineered the drawings. The court noted that the burden of proof was on the TAFE, and mere allegations were insufficient.
   7. The court held that the TAFE did not discharge this burden, the similarities were not sufficient to infer infringement in a field where standardization is common.
   8. The court observed, Copyright law is not intended to create a monopoly broader than patent or design law.
4. Remedies & Costs
   1. Because infringement was not established, TAFE was not granted injunction, damages, or any other remedies. The Suit was dismissed by the Court.
   2. Both parties were directed to bear their own costs.

Key Takeaways

1. Copyright protection for industrial drawings is distinct from design protection; Section 15 of the Copyright Act does not apply if the drawings are not designs under the Designs Act.
2. Burden of proof: Plaintiff must establish both originality of drawings and copying/access by the SCIL of the alleged drawings. The TAFE needed to show access to confidential drawings or direct evidence of copying which was not established in this case.
3. Industry standards: Similarity in parts due to standardization does not automatically imply copyright infringement. Protection under copyright is limited, especially when the features in question are dictated by industry standards and not by creative choices.
4. Reverse engineering: The judgment emphasized that indirect copying (including reverse engineering) should not be inferred lightly, especially in technical fields where standardization is common.

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