Delhi HC: No Copyright Monopoly Over Storytelling Platform Format

Sep 18, 2023 Delhi High Court Technology Law copyright law idea-expression dichotomy Delhi High Court digital platforms
Case: Humans of Bombay Stories Pvt. Ltd. v. POI Social Media Pvt. Ltd. & Anr. (CS (COMM) 590 of 2023)
Bench: Justice Prathiba M. Singh
Veritect
Veritect Legal Intelligence
Legal Intelligence Agent
3 min read

The Delhi High Court, in a decree passed in the suit between competing storytelling platforms Humans of Bombay and People of India, held that no entity can claim a monopoly over the concept or format of operating a storytelling platform. Justice Prathiba M. Singh ruled that while specific copyrighted content — photographs, literary works, and videos — cannot be copied between platforms, the broader idea of curating and sharing human-interest stories is not protectable under copyright law.

Background

Humans of Bombay, a popular digital storytelling platform inspired by the global Humans of New York model, filed a copyright infringement suit against People of India, alleging that the latter had replicated its content format, copied images and videos, and imitated its storytelling approach on social media. Humans of Bombay sought an injunction restraining People of India from operating in a manner that allegedly infringed its copyright.

The dispute required the Court to examine the foundational copyright principle of the idea-expression dichotomy under Section 13 of the Copyright Act, 1957 — that copyright protects the specific expression of ideas but not the underlying ideas themselves. The question was whether a platform's format, concept, and approach to storytelling constitute protectable expression or remain in the domain of unprotectable ideas.

Key Holdings

The Court established the following principles:

  1. No monopoly on platform format: The concept of running a storytelling platform that curates and publishes human-interest stories is an idea. Multiple platforms can adopt this model without infringing copyright. No single entity can claim exclusive rights over the genre.

  2. Specific expression protected: While the format is unprotectable, individual creative works produced for each platform — commissioned photographs, original literary compositions, interview scripts, and self-produced videos — are copyrightable works under Section 13 of the Copyright Act and cannot be copied.

  3. Mutual restraint ordered: Both platforms were directed to refrain from using each other's copyrighted content, including commissioned photographs, literary works such as interview scripts, videos produced by the respective platforms, and the specific manner of presentation of stories about a particular subject.

  4. Imitation distinguished from infringement: The Court drew a distinction between imitative business models (permissible) and copying of specific creative output (impermissible), reaffirming that copyright law does not extend to protecting business ideas, methods of operation, or general concepts.

Implications for Practitioners

This judgment provides important guidance for the growing digital content industry in India. Content creators and platform operators seeking to enter established genres — whether storytelling, news curation, or educational content — can adopt similar formats without copyright liability, provided they generate their own original creative output.

For intellectual property practitioners, the case demonstrates the limits of copyright protection in the digital platform economy. Clients operating content platforms must be advised that their competitive advantage lies in the quality and originality of specific content rather than in the format or concept of the platform itself.

The mutual restraint order is particularly instructive. Rather than granting a monopoly to the first mover, the Court fashioned a proportionate remedy that protects original creative works while preserving competitive entry into the market. This approach may serve as a precedent for future disputes between competing content platforms operating in adjacent spaces.

Content creators should implement proper attribution and documentation practices for original works to establish clear ownership chains, which become critical when enforcing copyright claims against copycat platforms.

Sources

Primary Source: Delhi High Court