The Chancellor, Masters & Scholars of the University of Oxford & Ors. v. Rameshwari Photocopy Services & Ors.

High Court of Delhi at New Delhi | Decided: 9 December 2016 RFA (OS) 81/2016 Bench: Division Bench Hon’ble Mr. Justice Pradeep Nandrajog & Hon’ble Mr. Justice Yogesh Khanna

Background

The appellants (plaintiffs before the learned Single Judge) were five academic publishers: Oxford University Press, Cambridge University Press (UK), Cambridge University Press India Pvt. Ltd., Taylor & Francis Group (UK) and Taylor & Francis Books India Pvt. Ltd. The dispute concerned the photocopying of pages from the plaintiffs’ copyrighted academic publications by Respondent No. 1, Rameshwari Photocopy Services, a shop licensed by the University of Delhi to operate within the precincts of the Delhi School of Economics. The evolved factual picture, notwithstanding an initial denial by the University, was that professors at the Delhi School of Economics had authorised the preparation of “course packs,” and Rameshwari Photocopy Services was entrusted with photocopying selected pages from the plaintiffs’ books, binding them and supplying them to students at 50 paisa per page.

The plaintiffs pleaded specific data concerning four course packs comprising photocopied extracts from a total of twenty-three distinct publications, with the percentage of each book copied ranging from as low as 0.05% to as high as 33.8% (one publication, “Issues in Political Theory,” had 141 of its 416 pages copied). Across all twenty-three works identified, the average percentage of each book copied was pleaded as 8.81% and the average price of the books was pleaded as Rs. 2542.

By order dated March 1, 2013, the Association of Students for Equitable Access to Knowledge (ASEAK) was impleaded as Defendant No. 3 and by order dated April 12, 2013, the Society for Promoting Educational Access and Knowledge (SPEAK) was impleaded as Defendant No. 4.

The plaintiffs’ case was that the preparation of course packs amounted to institutional sanction for copyright infringement; that the course packs, containing no material beyond photocopies of the plaintiffs’ copyrighted works, were being used as substitutes for textbooks and thus competed commercially with the plaintiffs’ publications; and that Rameshwari Photocopy Services was operating commercially, charging 40–50 paisa per page as against a market rate of 20–25 paisa charged by other photocopiers for student-supplied material. The plaintiffs anticipated a defence under Section 52(1)(i) of the Copyright Act, 1957 and pleaded in advance that this provision did not apply because the reproduction was carried out by Rameshwari Photocopy Services with University assistance, not directly “by a teacher or a pupil.” The plaintiffs further pleaded that Section 52(1)(i) covered reproduction “in the course of instruction” only and not “in the course of preparation for instruction” relying on the legislative history showing that the latter phrase, present in the original Bill, had been replaced with the former in the enacted statute. The plaintiffs contended the activity instead fell within Section 52(1)(h), which limits reproduction to two passages from works by the same author published by the same publisher within any five-year period and relied on Article 9 and Article 10 of the Berne Convention, 1886 and Article 13 of TRIPS, 1995, as well as foreign decisions including Princeton University Press v. Michigan Document Services Inc., Province of Alberta v. Canadian Copyright Licensing Agency and Basic Books Inc. v. Kinko’s Graphics Corporation, to argue that the University should be directed to obtain licences from the Indian Reprographic Rights Organization (IRRO).

Rameshwari Photocopy Services contested the plaintiffs’ copyright and pleaded that its activity constituted fair use under Sections 52(1)(a) and (h) of the Copyright Act, 1957 and that it did not affect the market for the plaintiffs’ books since students could not afford to purchase all prescribed books. The University of Delhi, adopting Rameshwari Photocopy Services’ position, pleaded that Section 52(1)(i) permits unlimited reproduction for educational purposes, distinguishing “reproduction” (used in clause (i)) from “publication” (used in clause (h), defined with reference to the “public” under Section 3). SPEAK and ASEAK, as interveners/defendants, advanced further arguments supporting an expansive reading of Section 52(1)(i), relying on the New Zealand decision in Longman Group Ltd. v. Carrington Technical Institute Board of Governors and the minority opinion in Princeton University Press.

The learned Single Judge held that since the University of Delhi had assumed full responsibility for the course packs, this amounted to a concession of the plaintiffs’ copyright and that the dispute reduced to a pure question of law not requiring trial. The Single Judge held, after extensive analysis, that Section 52(1)(i) permitted reproduction “in the course of instruction” expansively interpreted to cover the entire academic session, was not subject to a quantitative or qualitative “fair use” limitation and dismissed the suit along with the application for interim injunction, holding no triable issue arose. The plaintiffs (along with interveners the Association of Publishers in India, the Federation of Indian Publishers and IRRO) appealed to the Division Bench.

Issues for Determination

1. Whether the reproduction of any work “by a teacher or a pupil in the course of instruction” under Section 52(1)(i) of the Copyright Act, 1957 is an absolute right unrestricted by any standard of fair use or whether it is subject to an implicit limitation that the reproduction be “fair” or justified by the purpose of instruction.
2. What is the correct interpretation and span of the phrase “by a teacher or a pupil in the course of instruction” in Section 52(1)(i)(i) specifically, whether it is confined to face-to-face classroom interaction or extends to the broader process of teaching including preparation of course material and whether institutional intermediation (a University-licensed photocopy shop) in the act of reproduction falls within or outside this protection.
3. Whether the term “reproduction” used in Section 52(1)(i) is distinct in meaning and scope from the term “publication” used in Section 52(1)(h) and what consequences flow from this distinction for the applicability of the two provisions to the preparation of course packs.
4. Whether Section 52(1)(h) which limits reproduction in instructional collections to two passages from works by the same author published by the same publisher within five years has any bearing on or limits the scope of Section 52(1)(i) or whether the two clauses must be read as independent, standalone provisions covering different fields.
5. Whether the four-factor “fair use” test developed in foreign jurisdictions (purpose and character of use, nature of the work, amount and substantiality used and effect on the market) applies to the interpretation of Section 52(1)(i) of the Indian Copyright Act, 1957 or whether Indian law requires a different standard tailored to the specific language of the Indian statute.
6. Whether the preparation of course packs by Rameshwari Photocopy Services, on the admitted facts and data pleaded by the plaintiffs (covering twenty-three publications with varying percentages of content copied), constituted activity protected under Section 52(1)(i) or whether this question required a factual trial with expert evidence to determine whether the extent of reproduction was “justified by the purpose” of instruction.
7. Whether the persuasive value of foreign judicial precedent from the United States, United Kingdom, Canada and New Zealand was appropriate for interpreting Section 52(1)(i) of the Indian Copyright Act, 1957, given the differences in statutory language and built-in fair use standards across these jurisdictions.
8. Whether the learned Single Judge was correct in holding that no triable issue of fact arose and in dismissing the suit and the application for interim injunction without trial.

Key Holdings of the Court

1. The Division Bench held that the right of reproduction by a teacher or a pupil “in the course of instruction” under Section 52(1)(i) is not absolute and that a standard of fairness must necessarily be read into the provision since fairness is implicit whenever a person’s labour (here, the copyright holder’s creative work) is being utilised by another, unless the statute expressly excludes such a reading. However, the court clarified that this standard of fairness is not the four-factor qualitative/quantitative test developed in foreign jurisdictions (purpose and character of use, nature of the work, amount and substantiality of the portion used and effect on the market), which the court expressly held inapplicable to Section 52(1)(i).
2. The court held that the appropriate touchstone for fairness under Section 52(1)(i) is whether the extent of reproduction of the copyrighted work was “justified by the purpose” namely, the purpose of instruction. The court held that this inquiry has no concern with the quantitative or qualitative extent of material used in the abstract; rather, so much of the copyrighted work may fairly be used as is reasonably necessary to make the learner understand what is intended to be understood, having regard to the course curriculum, course content and prescribed reading material.
3. The court held that the expression “in the course of instruction” must be interpreted widely, to mean “an integral part of a continuous progress” of the entire process of education commencing with the teacher’s preparation, setting of the syllabus and prescription of reading material and continuing through the academic session, classroom or tutorial interface, testing and clarification of doubts and is not confined to the moment-to-moment interaction of a teacher delivering a lecture in a classroom. The court agreed with this aspect of the learned Single Judge’s reasoning and with the persuasive reasoning of the New Zealand High Court in Longman Group Ltd. v. Carrington Technical Institute Board of Governors that “the course of instruction” includes anything in the process of instruction commencing earlier than and ending later than, the time of formal instruction itself.
4. The court held that the term “reproduction” in Section 52(1)(i) is distinct from “publication” in Section 52(1)(h). The court held that “publication,” properly understood with reference to Section 3 of the Act, carries an element of commercial profit and dissemination to a “public” (which need not mean all members of the community but does require a targeted audience and a profit motive), whereas reproduction by a teacher for use in the course of instruction lacks that profit element. The court further clarified correcting the learned Single Judge that “publication” need not mean availability to all members of a community; a targeted audience (such as doctors purchasing a medical text) would also constitute a “public,” but the decisive distinguishing factor between Section 52(1)(h) and Section 52(1)(i) is the presence or absence of a commercial/profit motive, not the size of the audience.
5. The court held that the existence of an intermediary (such as a University-licensed photocopier) in the physical act of reproduction does not take the activity outside the protection of Section 52(1)(i), since neither teachers nor pupils could realistically be expected to personally operate photocopying machines and the substance of the activity photocopying for instructional use remains the same irrespective of whether the copying is done by the teacher, the pupil or an agent acting on their behalf or at the University’s instance.
6. The court held disagreeing in part with the reasoning, though not the ultimate conclusion, of the learned Single Judge that the correct test for assessing whether a course pack falls within Section 52(1)(i) is not whether the compilation has, on its facts, become indistinguishable from a “textbook” (the approach taken by the New Zealand High Court in Longman’s case), but rather whether the inclusion of each copyrighted extract in the course pack was justified by the instructional purpose for which it was included having regard to the course objectives, course content and the syllabus or reading list prescribed by the teacher. The court held that this inquiry was inherently fact-sensitive and required expert evidence.
7. The court held that decisions of courts in the United States, United Kingdom and Canada had no persuasive value in interpreting Section 52(1)(i), because the statutes in those jurisdictions contain express, built-in “fair use” or “fair dealing” standards (Section 107 of the U.S. Copyright Act; Sections 6(1)–6(2) of the U.K. Copyright Act, 1956; Section 29 of the Canadian Copyright Act) that are fundamentally different in structure from the Indian provision. The 1991 New Zealand decision in Longman’s case was held to have persuasive value, particularly regarding the wide interpretation of “in the course of instruction,” but the court declined to follow its “textbook” test and the 2002 New Zealand decision in Copyright Licensing Authority v. University of Auckland (interpreting the post-1994 amended New Zealand statute, which contains express percentage limits) was held to have no relevance to the Indian statute, which contains no such express quantitative limitation.
8. The court held that Article 9 of the Berne Convention and Article 13 of TRIPS, being directory and leaving considerable latitude to signatory states in framing domestic exceptions for educational use, did not constrain the interpretation given to Section 52(1)(i) and that the legislative history (including statements made in Parliament while piloting the 2012 Amendment Bill) supported a liberal interpretation favouring educational access.
9. The court held that no fair dealing standard could be read into Section 52(1)(h) so as to limit Section 52(1)(i), as the two clauses operate independently and deal with different fields of activity (compilations intended for sale/publication versus reproduction in the course of instruction), correcting the Single Judge’s reliance on the Division Bench’s earlier decision in Syndicate of the Press of University of Cambridge v. B.D. Bhandari (which the court distinguished on its facts, since that case concerned commercial guidebook publishers who were neither teachers nor pupils).
10. The court held that the learned Single Judge erred in concluding that no triable issue of fact arose. The court held that the question whether the specific extracts reproduced in the four course packs in question were “justified by the purpose” of the respective courses was a mixed question of fact and law requiring expert evidence regarding the course objectives, content and prescribed reading lists and was therefore not capable of summary determination. The court additionally identified a second triable issue arising from a Local Commissioner’s report dated August 27, 2012, which recorded that, apart from the course packs, eight entire books had been found photocopied (in varying numbers of copies) at the premises of Rameshwari Photocopy Services raising the separate question whether photocopying of entire books could ever be a permissible activity under Section 52(1)(i).
11. The Division Bench set aside the impugned judgment and decree of the learned Single Judge, restored the suit for trial on the two identified triable issues and permitted the parties to lead expert evidence. The court declined to grant an interim injunction to the appellants but directed Rameshwari Photocopy Services to maintain a record of course packs photocopied and supplied to students, to be filed in the suit every six months. Parties were directed to bear their own costs of the appeal.

Statutory Provisions Involved

Section 13 of the Copyright Act, 1957 enumerates the classes of works literary, dramatic, musical and artistic works, cinematograph films and sound recordings in which copyright subsists, forming the foundational basis of the plaintiffs’ claim to copyright in their academic publications.

Section 14 of the Copyright Act, 1957 defines the bundle of exclusive rights of the copyright owner, including the right to reproduce the work in any material form (Section 14(a)(i)) and the right to issue copies of the work to the public (Section 14(a)(ii)), extending to “any substantial part” of the work. The court’s analysis of whether photocopying constitutes “reproduction” and whether the principle of exhaustion (per the Explanation to Section 14) was relevant was grounded in this provision, as discussed by the learned Single Judge and reviewed by the Division Bench.

Section 51 of the Copyright Act, 1957 defines the circumstances constituting infringement of copyright, including the doing, without licence, of any act the exclusive right to do which is conferred upon the copyright owner under Section 14. The relationship between Section 51 and Section 52 specifically, whether Section 52 operates as a “proviso” or “exception” to Section 51 or as an independent declaration of non-infringing acts was a central interpretive question, with both the learned Single Judge and the Division Bench (and counsel for all parties) agreeing that Section 52 is not to be read as a proviso or exception to Section 51, but rather as defining a category of acts that fall outside the scope of the exclusive rights conferred by Section 14 altogether.

Section 52(1)(a) of the Copyright Act, 1957 protects “fair dealing” with any work (other than a computer programme) for purposes including private or personal use (including research), criticism or review and reporting of current events. The court held this clause inapplicable to the course pack dispute, since the photocopying in question was for instructional use under clause (i), not private research or criticism under clause (a) and criticised the Single Judge’s alternative reasoning that multiplication of private copying (clause (a)) by individual students would justify the activity under clause (i), holding that the two clauses operate on distinct legal bases.

Section 52(1)(h) of the Copyright Act, 1957 permits the publication, in a collection mainly composed of non-copyright matter and bona fide intended for instructional use, of short passages from published literary or dramatic works, limited to not more than two such passages from works by the same author published by the same publisher within any five-year period. This provision, central to the plaintiffs’ case, was held by the court to be a standalone provision dealing with commercial publication of compilations, distinct from and not limiting Section 52(1)(i).

Section 52(1)(i) of the Copyright Act, 1957 is the central provision of the judgment, providing that the reproduction of any work by a teacher or a pupil in the course of instruction or as part of examination questions or answers, does not constitute infringement of copyright. The Division Bench’s extensive interpretation of the scope of “reproduction,” “teacher or pupil,” and “in the course of instruction” under this clause is the doctrinal core of the decision.

Section 2(m) of the Copyright Act, 1957 (definition of “infringing copy”) and Section 3 of the Copyright Act, 1957 (definition of “publication,” as making a work available to the public) were relevant to the court’s analysis distinguishing “reproduction” from “publication” as used respectively in clauses (i) and (h) of Section 52(1).

Article 9 and Article 10 of the Berne Convention for the Protection of Literary and Artistic Works, 1886 and Article 13 of the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS), 1995, were invoked by the plaintiffs to argue that any domestic exception to copyright must not conflict with the normal exploitation of the work and must not unreasonably prejudice the legitimate interests of the rights holder. The court held these provisions to be directory in nature, leaving substantial discretion to India as a signatory state in framing the precise contours of its domestic educational exception.

Reasoning of the Court

The Division Bench’s reasoning proceeded along several interlocking tracks. At the outset, the court cautioned itself against uncritical reliance on foreign precedent, observing that while winds from across the border should be welcomed, care must be taken to filter what is transplantable given differences in statutory language across jurisdictions a caution that shaped the court’s subsequent, jurisdiction-by-jurisdiction assessment of the comparative case law cited by both sides.

On the question of whether fairness must be read into Section 52(1)(i), the court reasoned that fairness in the use of another’s labour is a general principle that must inform statutory interpretation unless expressly excluded by the legislature and that since Section 52(1)(i), unlike Section 52(1)(a), does not expressly incorporate “fair dealing” as a textual limitation, the general principle of fair use rather than the specific four-factor American-style test should be read into the clause. The court grounded this fairness standard in the singular touchstone of whether the use of the copyrighted material was “justified by the purpose” of instruction, reasoning that to “utilise” a work means to make it useful for the purpose at hand and that the extent of permissible use should track the pedagogical necessity of the material rather than any predetermined quantitative ceiling.

On the scope of “in the course of instruction,” the court engaged in a granular textual exercise, examining dictionary meanings of “instruction,” prior Indian case law interpreting the phrase “in the course of” in other statutory contexts (drawing an analogy across diverse fields including income tax and labour law) and concluded that the phrase denoted an integral, continuous process beginning with a teacher’s preparation of syllabus and reading material and continuing through the full span of an academic term rather than being confined to literal, real-time classroom delivery. The court found support for this reading in the New Zealand High Court’s decision in Longman’s case, notwithstanding the explicit presence of the word “correspondence” in the New Zealand statute (which counsel for the appellants had argued rendered the New Zealand reasoning inapplicable); the Division Bench held that the New Zealand court’s interpretation of “course of instruction” did not, in substance, depend upon that word and that its core reasoning that the course of instruction encompasses preparatory and subsequent activity connected with teaching was independently persuasive and consistent with ordinary English usage.

On the distinction between “reproduction” and “publication,” the court undertook a corrective exercise vis-à-vis the Single Judge’s reasoning, accepting the appellants’ submission (grounded in Copinger and Skone James on Copyright) that “publication” does not require dissemination to the entire community but only to a “targeted audience” possessing a public character, while clarifying that the truly decisive distinguishing feature between Sections 52(1)(h) and 52(1)(i) is the presence of a commercial or profit motive in the former and its absence in the latter reproduction by a teacher for instructional use, without an associated profit element, falling outside “publication” regardless of how many pupils receive the material.

On the question of institutional intermediation, the court applied common sense reasoning: since neither teachers nor pupils would realistically operate a photocopier themselves, the involvement of a licensed photocopy shop acting at the instance of the teacher or University did not convert the underlying activity (photocopying for instructional use) into something different in legal character. The court further examined and rejected on the facts pleaded, the allegation that Rameshwari Photocopy Services was making a profit beyond the ordinary photocopying margin; documentary evidence (the licence permitting a maximum charge of 40 paisa per page as of January 2012) was found to undercut the plaintiffs’ unsubstantiated claim of a 50-paisa rate generating extraordinary profit.

On the comparative law survey, the court systematically distinguished the eleven foreign decisions cited by counsel. United States decisions (Princeton University Press, Basic Books v. Kinko’s, American Geophysical Union, Williams & Wilkins, Cambridge University Press v. Patton/Becker) were held inapplicable because Section 107 of the U.S. Copyright Act expressly enumerates a detailed four-factor fair use test absent from the Indian provision. The U.K. decision in Sillitoe v. McGraw-Hill was held inapplicable because it interpreted Sections 6(1)–6(2) of the U.K. Copyright Act, 1956, which expressly build “fair dealing” into the relevant exceptions, relevant instead (if at all) to Section 52(1)(a) of the Indian Act. The Canadian decision in Alberta v. Canadian Copyright Licensing Agency was similarly distinguished because the analogous Canadian provision (Section 29) has fair dealing built into its text. Among the New Zealand decisions, Longman’s case (1991, interpreting the pre-1994 New Zealand statute, structurally closer to the Indian provision) was found persuasive on the “course of instruction” point but was declined on its ultimate “textbook” test, while the 2002 Auckland decision (interpreting the post-1994 amended New Zealand statute with express percentage caps) was held wholly inapplicable, since the Indian statute contains no comparable numerical limitation.

The court also revisited and distinguished its own Division Bench precedent in Syndicate of the Press of University of Cambridge v. B.D. Bhandari, clarifying that the earlier decision’s discussion of “fair use” arose in the specific context of commercial guidebook publishers who fell outside the protection of the analogous pre-2012 provision altogether because they were neither teachers, pupils, nor persons giving or receiving instruction and were reproducing for commercial gain and that this did not establish a general fair dealing overlay applicable to all clauses of Section 52(1), including clause (i).

Having thus charted the correct legal framework, the court turned to the application of that framework to the facts and found that this application could not be resolved on the existing record. Determining whether the inclusion of each specific extract in the four course packs was “justified by the purpose” of the relevant course required an examination of the course curriculum, the objectives of the course, the totality of the prescribed reading list and the role each extract played within that pedagogical design none of which could be assessed without expert evidence. The court therefore restored the suit for trial on this issue, employing a musical metaphor that in the “melody” of a statute, different provisions may at different times need to be allowed to predominate over others without entirely silencing them to explain why Section 52(1)(i), in appropriate and limited circumstances, may permit substantial reproduction without thereby rendering the limitations of Section 52(1)(h) superfluous, since the two clauses operate in genuinely distinct fields.

A second and independent triable issue was identified from the Local Commissioner’s report disclosing photocopying of entire books (in multiple copies for some titles) on the premises, an activity the court considered raised a distinct question whether reproduction of an entire work could ever be “in the course of instruction” within the meaning of Section 52(1)(i) that had not been pleaded or addressed at the time of the original suit and required the plaintiffs to be permitted to amend their pleadings.

Doctrinal Significance

The judgment in The Chancellor, Masters & Scholars of the University of Oxford & Ors. v. Rameshwari Photocopy Services & Ors. widely known as the “DU Photocopy Case” is among the most significant and extensively analysed decisions in Indian copyright law concerning the educational use exception under Section 52(1)(i) of the Copyright Act, 1957. Its doctrinal influence extends well beyond the specific dispute between academic publishers and a university photocopy shop, shaping the broader Indian understanding of the balance between copyright protection and the constitutional and social value of equitable access to education.

The judgment’s most enduring contribution is its articulation of a distinctively Indian standard for fair use under Section 52(1)(i) namely, that the touchstone is whether the extent of reproduction is “justified by the purpose” of instruction, rather than the importation of the American four-factor test or any fixed quantitative ceiling. This purpose-justified standard avoids both the rigidity of a percentage-based cap (as found in the post-1994 New Zealand statute) and the multi-factor balancing complexity of U.S. fair use doctrine, instead anchoring the inquiry in the pedagogical relationship between the material reproduced and the specific instructional objective it serves. This approach has been widely discussed in subsequent Indian scholarship and litigation as a contextually appropriate solution suited to India’s developmental needs, where the availability of imported academic texts is often constrained by cost and access, particularly for students in public universities.

The judgment’s wide reading of “in the course of instruction” extending the phrase to the entirety of the teaching-learning process rather than literal classroom presence has significant practical consequences for Indian educational institutions, since it provides a textual basis for course-pack preparation, reading-list compilation and pre-class distribution of instructional material to be treated as falling within the protective ambit of Section 52(1)(i), provided the purpose-justification standard is satisfied on the facts.

The judgment also performs an important function in clarifying the relationship between different clauses of Section 52(1) of the Copyright Act, 1957 confirming, against a contrary submission, that the clauses must generally be read as standalone provisions governing distinct fields of activity (here, commercial publication of instructional compilations under clause (h) versus direct reproduction in the course of teaching under clause (i)), rather than one clause limiting or controlling the interpretation of another by negative implication. This principle of independent, standalone interpretation of the sub-clauses of Section 52(1) has continuing relevance for the interpretation of the Act’s other exceptions.

The court’s careful, jurisdiction-by-jurisdiction methodology for assessing the persuasive value of foreign case law turning on whether the foreign statute contains an express, built-in fair use or fair dealing standard comparable to or different from the Indian provision under consideration offers a valuable interpretive template for Indian courts engaging with comparative copyright jurisprudence more generally, cautioning against indiscriminate transplantation of foreign reasoning without close attention to underlying statutory architecture.

Finally, the judgment’s ultimate disposition restoring the matter for trial on specific, narrowly identified triable issues rather than either wholly affirming or wholly reversing the Single Judge’s dismissal reflects an important procedural lesson: that even where a court articulates broad principles of statutory interpretation with confidence, the application of those principles to a complex factual matrix (in this case, the pedagogical justification for twenty-three distinct extracts across four course packs and the separate question of whole-book photocopying) may still require a full evidentiary trial. The case proceeded to trial following this remand and was the subject of further proceedings, including the eventual withdrawal of the suit by the publisher-plaintiffs in 2017, but the Division Bench’s articulation of the governing legal principles in this 2016 judgment remains the authoritative statement of Indian law on the scope of the educational reproduction exception under Section 52(1)(i) of the Copyright Act, 1957.

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