University of Oxford v. Rameshwari Photocopy Services

Educational use of copyrighted works can be lawful when it serves teaching and learning without commercial exploitation.

Summary

This case is one of the most significant Indian decisions on copyright exceptions for education. Leading academic publishers, including the University of Oxford, sued a photocopy shop operating within Delhi University for reproducing portions of copyrighted textbooks and selling course packs to students. The Delhi High Court examined whether such copying amounted to infringement or fell within the statutory exception for educational use under the Copyright Act, 1957.

Facts of the Case

Rameshwari Photocopy Services operated a shop inside the Delhi University campus and prepared course packs containing photocopied extracts from various textbooks prescribed by professors. The publishers argued that systematic photocopying of substantial portions of their books harmed the market for original textbooks and amounted to commercial exploitation. The defendants contended that the copying was strictly for classroom instruction, based on teachers’ directions, and affordable access to education for students.

Findings / Reasoning

The Delhi High Court held that Section 52(1)(i) of the Copyright Act permits reproduction of copyrighted works for the purpose of instruction. The Court interpreted “course of instruction” broadly, holding that it includes preparation of course packs as part of teaching activities. It emphasized that copyright law must be interpreted in a manner consistent with constitutional values such as the right to education. Since the copying was non-exploitative and limited to academic instruction, it did not constitute infringement.

Suggestions / Observations

The judgment underscored the need to balance copyright protection with public interest in education. It observed that excessive restriction would make education inaccessible to a large section of society. At the same time, the Court clarified that the exception applies only to genuine instructional use and not to large-scale commercial reproduction unrelated to teaching.

Judgment & Date

The Delhi High Court dismissed the publishers’ suit and held that preparation of course packs for educational instruction fell within the statutory exception and did not infringe copyright.

Judgment Date: 16 September 2016