Mannu Bhandari v. Kala Vikas Pictures Pvt. Ltd.
Rule established
Moral right of integrity violated when film adaptation distorts literary work to the prejudice of author's honour/reputation
Facts
- Mannu Bhandari wrote "Aap Ka Bunty" (1971), a critically acclaimed Hindi novel
- She assigned film rights to Kala Vikas Pictures
- The screenplay substantially altered plot, characters, and narrative perspective
- Bhandari objected to distortions as harmful to her literary reputation
- She sought injunction against release in modified form
Issues
- Whether an author who assigned film rights retains moral rights to object to distortions
- Scope of the right of integrity in Indian copyright law
Held
- Assignment of economic rights does not extinguish moral rights
- Author retains the right to object to modifications prejudicial to honour or reputation
- The modifications were substantial enough to potentially prejudice the author
- Court balanced producer's investment against author's moral rights
Ratio Decidendi
Moral rights are personal, inalienable, and survive assignment. The right of integrity protects against distortion prejudicial to reputation. Film producers have creative latitude but not unlimited licence to deface the underlying work.
How to use it in an exam
- Leading pre-S.57 authority on moral rights in India
- Cite in IPL questions on author's moral rights and film adaptation
- Pair with Amar Nath Sehgal v UOI (2005) for moral rights in visual art
Source
Source: AIR Online
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.
Cited in study notes
LawBerne Convention 1886 and WCT 1996Moral right of integrity violated when film adaptation distorts literary work to