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Inadequacies of Indian Industrial Property Rights Regime.

Inadequacies of Indian Industrial Property Rights Regime.
Authors: Adv. R. Muralidharan[1], Advocate and Mediator, Patent & Trademark Attorney, Manu Associates, Bangalore  and Ms. Anupama S Pillai, Advocate, Manu Associates, Bangalore.

1.   Indian IPR policy

On 12th May 2016, Department of Industrial Policy & Promotion, Ministry of Commerce & Industry, Government of India published the National Intellectual Property Rights Policy 2016 and it was approved by the Cabinet on 13th May 2016. The Policy is the brain child of a 6 member Committee, the Think-Tank - headed by Justice Prabha Sridevan, a former judge (Madras High Court) and former chairperson of the Intellectual Property Appellate Board (IPAB). Other members of the Think Tank are :- Prathiba Singh [Senior Advocate]; Punita Bhargava[ Advocate, Inventure IP] ; Unnat Pandit, [Cadila Pharmaceuticals]; Rajeev Srinivasan, [Director, Asian School of Business]; and Narendra Sabharwal, [Retired DDG, WIPO].

While the current members are accomplished, knowledgeable and persons of integrity, the Think Tank did not include a possible representation for foreign applicants who file the maximum number of patent applications in India. After all, one must recognize that the Patent system is primarily meant to protect public interest; this demands respect for IP Rights. In today’s scenario, most of the Applicants (above 80%) are of Foreign origin. Some of them, particularly those belonging to the U.S. have complaints and they occasionally become subjudice before International forums and sovereign institutions regulating global trade policies. Hence, the Think Tank   should be broader based, and include representatives from the Foreign/Indian commercial entities which spend substantial    money on research and development.

           2. New Organizational Structure for IPR Regime Administration
As of now, IPR Administration in India comes under the ambit of different Ministries of the Union of India. For example, Patent Design and Trade Marks Office is an Independent Statutory Functionary coming under the  Ministry of Commerce and Industry. The Copyright Office comes under the Ministry of Human Resource Development. Protection of Plant Varieties and Farmers Rights comes under the Ministry of Agriculture. Topography of Integrated Circuits Act Registration comes under Ministry of Communications and IT. This is not conducive to the promotion of an IPR culture. It is necessary to have a full-fledged Department of Industrial Property, headed by some of the IPR Cadre Officers, which will exercise overall control of administering IPR Regime in India. The proposed department of Industrial Property can draw people from the legal profession and include/consist of people from the other IPR departments who are currently administering the regime. Ensuring that this Independent organizational structure is headed by a Joint Secretary or a Secretary is absolutely necessary to minimize conflicts that will be inherent in any multidepartment control.
3. Do we need New Additional Legislations in IPR?
About 30 years ago, an IPR law student in India studied only Patent, Trademark, Copyright, and Design. Today, in addition to the above classical IPR, the curriculum includes Geographical Indications, Protection of Plant Varieties and Farmer’s Rights, Semi-Conductor Chips, Trade Secrets, and Valuable Commercial Information under Common Law. But, in India we do not have some types of IPR which other countries have found to be useful and hence, are today, a part of their IPR System. These are:
a)         Law of utility model:
These are peculiar to Continental and Civil Law countries. They are different from patent in that they do not insist on ‘Inventive Steps’. But, like Patent, they insist on Novelty, Utility, and Statutory Subject matter. The applicants should themselves do a bonafide search on novelty and make a declaration. They have a reduced span of protection. These are not available for process but only for products. Normally, for products having a design element, Applicant applies for both Patent and Utility Model Protection. The grant occurs within 6 to 9 months of the application as there is no preceding examination. The Applicant opts for Patent Protection if there is a favorable Examination Report on Inventive step in their patent application. This protection is particularly best suited to grass root rural inventors who may have satisfied the requirement of Novelty, Utility, and Statutory Subject matter but not inventive steps. In fact, Industrial Commercial Organizations of India have been demanding the introduction of Utility Model System. It is gratifying to note that the Think Tank has recommended the enactment of Utility Model protection.
b)        Pharma focused new generation of IPR:
Nowadays, there is a mind block, bordering on prejudice, relating to the health care inventions. We have the words of Madam Indira Gandhi, at WHO, that the inventions relating to human and animal health must be freely available to all, unfettered by commercial monopoly. Current Indian Patent Law implements the letter and spirit of Mrs. Gandhi’s wishes. However, in the interests of the Indian Pharma Industry, it is time that we consider whether we should have the following new generation IPR as part of our IPR system: -
                               I.            Data Exclusivity:
Introduction of a new drug or a new combination of earlier approved drugs requires Marketing Approval from Drug Controllers around the world. It is estimated that often, the cost of obtaining regulatory approval is between 5 to 10 times the cost of generating new molecules. In the course of obtaining regulatory approval the companies spend a lot of money on research relating to the method, conduct of clinical trials, analysis of data, etc. In the U.S.A., the results are protected under Hutch-Waxman Act and Europe also provides for similar protection. If Indian Companies are going to develop new molecules as opposed to the present generic drug business, the enactment of data protection laws in India may be absolutely necessary.
In this connection Satwant Reddy Committee[2] recommended enactment of laws in India for the protection of Data Exclusivity under patent laws. However, the above committee had recommended a much-watered down version in comparison with global peers.
                           II.            Orphan Drug/Generic/Pediatric/Exclusivities:
U.S. Laws provide 5 years protection for the Orphan Drugs i.e. for drugs meant for rare diseases having fewer patients and Generic Exclusivity of 120 days for those who introduce a new cheaper generic drug in place of patented medicine to substitute the more expensive Patented Drug, Pediatric Exclusivity, etc. If Indian Pharmaceutical Industry is to grow in a vibrant way and if India aspires to become a supplier of research developed drugs, to the world, the Think Tank should necessarily consider whether these types of rights are desirable in the present Indian context.

                        III.            Traditional Knowledge Protection:
Of late, it has become fashionable amongst nationalistic intelligentia to demand that there must be some kind of legal protection for Traditional Knowledge in India. However, this demand overlooks the fundamental truth that any Traditional Knowledge is part of public domain, incapable of appropriation by anyone. It is like the fishes located in high seas beyond territorial and exclusive economic zones of a country, which can be fished by anyone in the world. This, jurisprudentially, falls under the Latin Maxim “res omnium communis”.
Making Traditional Knowledge capable of appropriation by the social groups; that are responsible for the generation and preservation of the Traditional Knowledge overlooks the second obstacle namely, none of these individual or social groups have made a serious demand for the protection of these rights. I doubt whether these groups will be able to afford the cost of registration and expenses to enforce them. Conferring these rights on the social groups and leaving the enforcement either to government agencies or NGOs, will only result in another form of IPR bureaucracy with no tangible benefit to the so called social groups who are the possessors (not owners) of the Traditional Knowledge.
Furthermore, it has to be understood that a modern welfare state runs on the economic principle that in a free market there must be perfect competition. Every IPR grants commercial monopoly which actually distorts the competition. Thus, every IPR is statutorily sanctioned exception justified by strong economic and ethical reasons. For an applicant to be entitled for a patent or plant variety monopoly, he must create something which was not originally there. After the period of monopoly, the technology in the patent enlarges into public domain adding thereby to the knowledge of the people. Over a period, this can become a part of Traditional Knowledge. Hence, there is no economic, social, or even ethical justification for grant of any monopoly over Traditional Knowledge.
Furthermore, even though the Indian Patent Act, 1970 prohibits the patentability of any Traditional Knowledge per se, but any improvement to Traditional Knowledge that meets the requirements of Novelty, Utility, Non-obviousness, and Statutory Subject Matter is patentable. Similarly, in India and many parts of the world, if a person rediscovers specific implementation solutions for lost Traditional Knowledge, there is no reason why he should be denied patent protection. Hence, there should not be any legislation for protecting Traditional Knowledge when the social groups that possesses the Traditional Knowledge are unable and unwilling to undergo the expensive process of IPR registration and its enforcement.
                         IV.            Protection of Computer Software:
At the moment, computer software in India is primarily protected under the umbrella of Copyright Laws as  “literary work”. It is well known that Copyright Law protects only “Method of Expression (form)” and not the “idea” (content) or its “commercial expression”. Thus, it is inappropriate to protect software under copyright laws.
Even though the Indian Patent Act, 1970 prohibits the patentability of software perse, the Patent Manual published by the Indian Patent Office does not totally rule out the patentability of the improved technical effect brought about by the employment of new software. The test of improved technical effect manifested in any product or process is different from the operation of the computer or the software. However, the monopoly provided under patent is much stronger in comparison with the protection under copyright law. The IT industry today is getting used to the concept of a non-exclusive, irrevocable, perpetual license on non-discriminatory terms. Software Patents will complicate the situation.
In addition to patent and software protection, the IT industry extensively uses “non-compete” and “non-poaching” obligations. An average employment contract in the IT industry contains a restrictive covenant on employees that will continue to operate even after the termination of contract of employment. This prima facie attracts the operation of Section 27 of the Indian Contract Act, 1872 which stipulates that agreement in restraint of trade shall be void.
Hence, it is necessary for the Think Tank to consider “sui generis” method of protecting computer software; if necessary, by merging the best aspects of both Patent Law and Copyright Law which will clarify the most fundamental contractual principle that a restrictive covenant in restraint of trade can be valid, if it is reasonable and for protecting the valuable commercial information which is protected under statute, or unprotected yet may be protected under the contract.
4. Reforms to Patent law in General:
A.        Review of Section 3 of the Indian Patent Act, 1970:
The present Indian Patent Law Regime draws its inspiration, substantially, from the Justice Rajagopala Ayyangar Committee Report. The Committee, in the  1960s, recommended a very strict, Patentee unfriendly Patent Regime considering the then prevailing socio-economic conditions which can be summed up as under:
a.         Between 1958 – 1970, India was a predominantly agricultural country, where 85% of the population was dependent on agriculture. There was no Indian Industry. The State was the driver and mover of Indian Economy, Private Industry was never allowed to grow because of “Licence and Quota Raj”. India was closed to foreign capital and adopted excessively protectionist measures in favor of state commercial monopoly in business matters resulting in a lot of inefficiency and waste. Importantly, there was no such thing as a Service Industry. All the above facts have undergone a drastic change. Today’s situation can be summed up as under:
(i)         Today 58% of Indians are involved in agriculture, contributing to just 18% of its GDP.
(ii)        India today is the supplier of good quality cheap Generic Drugs to the world. Notwithstanding the occasional ban of reputed Indian manufacturers, the State of Andhra Pradesh boasts of the maximum number of U.S. FDA approved manufacturing facilities anywhere, outside the U.S., (even when the whole of Europe is considered as a single unit.) India, today, is the generic drug capital of the world.
(iii)India constitutes 5% of Global Territory, has roughly 20%    of  global population and 20% of share in the global digital traffic. Indian IT and Business Process Outsourcing (BPOS) companies have set the bench mark in the Global Software Industry.
(iv)Thanks to the reforms in Higher Education which resulted in the proliferation of Indian Universities, India today has many Universities. Many of these Universities are committed to achieving excellence and are producing more engineers and scientists than the Indian industry can reasonably absorb. Hence, from being the exporter of low-value indentured labour between 1780 and 1850, today we have become an exporter of high value Human Resources to many parts of the developed world.
(v)        Many Indian Companies are becoming Multinational Companies. Reliance, TATA, Infosys and WIPRO, Dr. Reddy, Ranbaxy, and Sun pharma have become Global brands. Even small and medium scale entrepreneurs have established commercial facilities in many South-Asian and African countries. There is a substantial outgo of Indian Capital for the establishment of Indian             controlled businesses in different parts of the world. Even though we welcome foreign capital, the facts speak for themselves: there is a substantial outgo of Indian capital for owning business located abroad. Hence, the view that India is a poor, developing, capital importing country warranting a strict patenting regime deserves reconsideration.
In the light of the above situation, we should reconsider our position on Patentable Subject Matter. Section 3 of the Indian Patent Act, 1970, contains 17 categories of Non-Patentable Subject Matter. Some of these exclusions were deleted but more exclusions were added. The Patent system is a reward for people and entities that make human life better by their innovations. The rationale behind Section 3 of the Indian Patent Act, 1970 namely that these categories of inventions are absolutely essential for facilitating the Socio-economic development of India overlooks this fundamental point. If these categories of invention are more significant for socio-economic development in India, then these categories should have even more significant protection than the rest!! Thus, in my opinion, Section 3 in its present             form goes against our important WTO TRIPS obligation viz. we will protect all innovations without discrimination.
This is not to say that Section 3 should be repealed. Many exclusions contained in Section 3 are the result of Judicial Decisions in the U.S. also, even though they do not have similar statutory provisions. In fact, if these foreign patent specifications are sufficiently Indianised by incorporating additional data and explanation, many of the so called non-patentable exclusions of Section 3             can be successfully overcome by a smart Patent attorney in India. 
(B)      Reforms to Section 39 of Indian Patent Act, 1970:
The published statistics of the Indian Patent Office revealed that 85% of applicants for patents in India are of foreign origin. Of the remaining 15% applicants, though the applicant may be Indian as a legal entity, there may be substantial foreign control. This is because these organisations spend more money on research and development and have a committed  budget for IPR acquisition and its enforcement.
India is fast becoming a research process outsourcing destination. This research process outsourcing is a higher margin Business Process Outsourcing. If the outsourced research to India results in an improvement, which by contract it would vest in the person who sponsored the research. Sometimes the foreign applicant will mention the Indian personnel who generated the invention in India. (Since, the foreign applicant has not complied with local filing requirement of Indian Law)When the foreign applicant applies for Indian Patent through PCT Route, the Patent Office can refuse patent for non-compliance of local filing requirement. As a patent professional, I am unable to comprehend the rationale behind this legislative provision except that the U.S.A. has it, therefore we have it. In India, the consideration that prevails in U.S.A. does not apply. It has been my experience that sometimes this provision applies cruelly on Indian innovators who are named as co-inventors or applicants            in a foreign patent when the foreign collaborator with better IPR culture take immediate steps for IPR registration in their respective territories, which may also have similar Local Filing Requirement. It is known that foreign entities altogether leave out the name of Indian Resident inventor from the declaration of Inventorship. Thus, this provision operates unjustly on Indian Innovators.
(C)      Reconciling the Apparent conflict between the operation    of Section 2(h) (Government Undertaking) and Section 47      (Government use of Patents) of the Indian Patent Act, 1970:
Every Patent is a proprietary Right in rem which is granted by the state after careful examination and scrutiny. Hence the patent should bind a state as much as any other commercial entity operating in its territory.
Under the Defense of Empire Rules, when a state requisitions  private property occupies and uses it (even for war and military purposes),( when the property is handed back to the owner), the state is obliged under common law, to pay compensation to the land owner. If patent is a proprietary Right in rem, then there is no reason to apply a different yardstick for allowing  Government use of patents.
Furthermore, nowadays the Union of India and many state governments own and control companies that are listed in the stock market, where lots of non-state     actors own substantial shares. These organisations essentially carry out commercial functions. Whichever way you look at it, a strict or liberal interpretation of these two sections will enable a government controlled entity or even NGOs that receive substantial funding from Government to get away with blatant acts of infringement. In this connection, it may not be out of place to mention the precedent in U.S.A. in Hughes Aircraft vs. NASA[3], when a direct state functionary executing sovereign acts agreed to pay compensation/damages to the patentee after the court ruled the existence of patent infringement.
True, Section 47 makes it clear that the government can use its patent, only for its “own purpose”. It is common knowledge that “own purpose” cannot include “commercial purpose”. If we have to follow the U.S. model, it is fair and reasonable that the state pays reasonable royalty (comparable to those given in        Compulsory Licensing cases) as and when a state or its instrumentality uses a Patented Technology. Definitely, listed commercial entities owned or controlled by the state cannot be allowed to get away with patent infringement and claim that it is government use of patent.
(D)Expropriation without compensation when the Patent Subject matter relates to biological materials.  
Form – 1 (Application for Patent) imposes  obligations on the use of any biological material endemic to India, without the applicant obtaining the permission from the  Indian National Biodiversity Authority(NBA). While granting such permission (which is an exercise of sovereign power), the NBA can declare itself as a joint owner of the IPR. This is, partial expropriation without compensation. This violates India`s obligation under Paris Convention and the Convention on Protection of Biodiversity. This unfairly discriminates against  foreigners who may become victims of this provision, even when the used Biological Material was from other parts of the world, if the material is considered as endemic to India in the opinion of NBA.
(E)Question of an Arbitrator pronouncing validity of a patent?
Usually, an International  transfer of technology agreement involves  Indian and Foreign Patents. The parties exercise their choice of law and often have dispute settlement by Arbitration. Under the Indian Arbitration Act ,the arbitrator may not have the required power to pronounce on the validity of a patent. This is because a patent is a right in rem and an arbitrator appointed to adjudicate the contractual rights of the parties may not have the legal competence to go into the question of validity of patent. In other words, until the patent is revoked or at least the operation of patent is stayed, the arbitrator has to proceed on the footing that the patent is valid. In case,the licensing agreement is terminated and the dispute involves pronouncing on the validity of the Patent, can an arbitrator sitting in an Indian forum decide on the validity of an Indian Patent?
Under section 294 of US Patent Act, the arbitrator has been specifically empowered to go into the question on validity of Patent. In such situations, his decision will be binding in between the parties.
Judicially, Patent is a right in rem and only public authorities like IPO, IPAB and High Courts can revoke the Patent. Thus, it can be argued that no arbitrator can pronounce on the validity of an Indian Patent. Hence, it might be necessary to make an amendment to Indian Patent Act clothing the arbitrator with power to pronounce on validity of the Patent.
(F) A Silver lining to a dark cloud.  
When the compulsory licensing provisions were first incorporated in the Indian Patent Act 1970, they attracted a lot of criticism from the United States of America and research driven pharma multinational corporations. In fact, all countries in the world have compulsory licensing provisions built in to their patent regimes. Even in United States where the IPR laws do not specifically empower the state to grant compulsory licenses the courts have may a time directed the parties to negotiate a compulsory licence to prevent Antitrust abuse. India steadfastly maintained supported to the Compulsory licensing provisions while reasonably safeguarding the interest of the patentees at the same time.
Over a period of time, other developing countries such as South Africa and Thailand, supported the position of the Union of India on the legal regime relating to grant of Compulsory licences  In fact, the present Indian regime on patent law incorporates new types of Compulsory licenses in addition to the ones prevailing under the 1970 Act. Sec 91 of the Patent Acts provided that related patents will also be available for Compulsory licensing. Sec 92 further provides for Compulsory licensing by notification by the Central government. Under the earlier Patent regime (1970) all pharmaceutical and food process patents automatically came under the ambit of licences of rights. Under the present Indian patent regime, this provision of licences of rights has suffered a silent repeal. However, when the Central Government issues notification under Sec 92 of the Indian Patent Act, then it will automatically amount to a “Licences of right” to be decided by Central government and as evidenced in the notification.
Furthermore, under the traditional patent jurisprudence Compulsory licensing is only to ensure that the Patented product is available in the local market at a reasonable cost. Normally, Compulsory licences are not meant for meeting an export demand. However, Sec 92 A of the Patent Act provides for Compulsory licensing even for catering to a foreign market. Thus, India is in the global forefront to ensure that Compulsory licensing provisions are essential for preventing Patent abuse.
Under the revised patent regime, the Patent office had opportunities to pronounce on two applications on compulsory licensing. In Bayer v. Natco (decided on March 04, 2013)the Indian Patent Office granted Compulsory licensing in favour of Nacto on the ground that the “Nexavar” patented medicine is not available in the Indian market both in terms of quantity and cost. However  the Patent Office and the IPAB ensured that there will be royalty rate of 6% of the sales turn over as opposed to the 2 to 4% recommend royalty as provided under UN procurement norms. The second case of Compulsory licensing BDR Pharmaceuticals v. Bristol Myers (decided on October 30, 2013)The Indian Patent Office held that the applicant for Compulsory licensing has not taken reasonable and diligent steps for procuring a voluntary license on mutually negotiated terms. Thus in all fairness it must be said to the credit of the Patent Office that they have been implementing the Compulsory licensing provisions fairly and justly.
(F) Another area of concern.
Indian Pharma patent regime continues to attract the attention and, in fact ,criticism of developed countries. Recently, the Honorable Supreme Court of India had upheld the decision of IPAB in the case of Glivic (Beta Crystalline form of Imatinibe Myselate). In this case the applicant was able to demonstrate that administration of the drug in the above form increases the bioavailability of the drug by another 30%, thereby facilitating ease of administration and better absorption of the product. However, the IPAB came to the conclusion that the word efficacy contemplated in Sec 3(d) explanation could only mean” therapeutic efficacy. The learned chairman of the IPAB (who subsequently became the Chairman of the IPR think Tank) while deciding the meaning of the word ‘efficacy’ instead of adopting the ‘golden rule of statutory interpretation’ chose to apply the ‘mischief rule of statutory interpretation’. In other words, the IPAB concluded that Sec 3(d)and its explanation were essentially for preventing the questionable practice of evergreening of patents by aggressively patenting even incremental innovations. However, one should be conscious of the fact that the expression ‘therapeutic efficacy’ is much more stricter than the expression ‘efficacy’. For e.g. if a product covered by the patent can be produced in a more environmentally friendly manner or at greatly reduced cost, from the point of view of the common man there is an improvement in efficacy. However, this will not constitute therapeutic efficacy as envisaged but the IPAB and subsequently upheld by the Supreme Court. However, considering that this litigation is just first of the many litigations which will occur in the future, one hopes that the Supreme Court will apply the golden rule in statutory interpretation and make the expression more just from the point of view of drug inventors.
INTERRELATION BETWEEN COPYRIGHT AND DESIGN
Design Act 2000 that replaced Design Act 1911 was expected to be more modern. But, alas, it retains its erstwhile primitive features!
a. Section 15 of Copyright Act
First, Section 15 of Copyright Act stipulates that where a copyright is registered, when under law, it ought to have been protected under Design Act, the Copyright protection would cease in respect of the article, when it is replicated more than 50 times by an individual process.
I guess this is unique to India. IP Attorneys all over the world do not put all their eggs in one basket. They may seek concurrent registration under Trademark, Patent, Copyright, Design, Semiconductor Integrated Circuits Layout-Design Acts etc. in respect of one product. Though, Jurisprudentially, Copyright infringement cannot be availed to injunct products embodying visual features, there is no reason to extinguish copyright/design protection. The Applicant musa be given a choice of election.  This provision should not promote unjust enrichment.
b. Inadequate Compensation in case of Piracy of registered design
In case of a design infringement, Compensation that can be granted is Rs. 25000/- per an act of infringement subject to a maximum of Rs. 50000/-. This ceiling is unreasonably low. Damages should depend on quantum of infringement and illegal profits made from infringing acts. But, this should be a good reason for the Courts to award interim relief, as compensation ceiling fixed by law makes the loss, irreparable within the meaning of ‘relative hardship doctrine’.
c. Reforms to Section 5(4) of Design Act 2000:
As per Section 5(4) of Design Act 2000, an appeal arising from the order of the Controller refusing an application for design, or an appeal arising from challenges to the validity of Registered Design lies with the High Court. Controller General of Patents, Designs and Trade Marks is the primary authority vested with the power of registration of Patents, Trademark, Designs and Geographical Indications. However, an appeal from the decision of the Controllers in matters of Patents, Trademark and Geographical Indications lies with the IPAB. Though the new IP policy propagates Administration and Management - to modernize and strengthen service oriented IPR administration, no effort is seen in the policy to consider IPAB as a comprehensive authority to decide appeals from Controller General of Patents, Designs and Trade Marks (CGPDTM).
Conclusions
About 30 years ago, IPR was not even taught as an optional subject in the law schools. Now, in many law schools, IPR is a compulsory subject. Even in those schools where it is optional, students opt for it in large numbers. In fact, many of the leading law schools offer some type of a continuing education program resulting in the award of a PG diploma in IPR. With all these developments, there is still a serious shortage of human resources in IPR Laws. In many ways, the perception of the general public and in fact a substantial section of the industry is very similar to the experience of four blind men feeling and describing an elephant. During 1980s, the number of people registered with Indian Patent Office as patent agent was well below 200. In 2017, the total number of patent agents hovers around 3000 compared , the United States’ Patent Office’s 30,000 patent agents. Hence it is absolutely necessary for law ,management and technology schools to promote IPR literacy in a big way. Many of the leading generic Indian pharma companies have serious plans to become research driven drug companies. The Indian IT revolution has increased the confidence level of general public. Yet, we are one of the very few counties in the world who declare themselves a socialist country. Again, we are unique in our constitutional declaration that the right to property is not a fundamental right but a merely a statutory right. The Directive Principles of the State Policy further declare that the state shall strive to ensure that the means of production are not concentrated in a few hands. Despite these constitutional reservations ,the Indian Parliament has granted legally enforceable statutory monopolies in favour of IPR owners. If we grant them a privilege, it must be a bonafide privilege. Other considerations should not prevent reasonable enforcement of these privileges.



[1] Manu Associates, Advocates and IPR Attorneys. NO.143/4, 8th Main, 14th Cross, Royal Fort Apartment, Malleshwaram,
Bangalore-560003
Phone-080-23346166
Mobile-0-9448247549

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