What did the court compare with UK law?

UK law separately recognises typographical arrangement. India’s law does not, showing fonts are treated differently and are not covered as artistic works.

What happened to the petitioner’s applications?

The Copyright Office had rejected the registrations. The High Court set aside the order only to allow a hearing, but clarified that fonts aren’t protected under Section 2(c).

If fonts aren’t copyrighted, what can creators do?

Creators can consider trademarks (for names/logos), design protection (for glyph designs, if eligible), licensing contracts, and technological measures.

Why is this case important for students?

It defines the boundary of ‘artistic work’ in India and warns that typeface creators must use other IP or contracts for protection.

Ananda Expanded Italics

Q: Are fonts protected by copyright in India?

No. The court said fonts/typefaces are not ‘artistic works’ under Section 2(c) of the Copyright Act, 1957, so they do not get copyright protection.

Ananda Expanded Italics (Req), re — 2002 (24) PTC 427

Do fonts count as “artistic works” under Section 2(c) of India’s Copyright Act? This case gives the straight answer for designers and students.

Calcutta High Court 2002 Single/Division (as applicable) 2002 (24) PTC 427 Copyright ~6 min read

CASE_TITLE: Ananda Expanded Italics (Req), re PRIMARY_KEYWORDS: fonts copyright India, Section 2(c), artistic work SECONDARY_KEYWORDS: typeface protection, typographical arrangement, Calcutta High Court PUBLISH_DATE: 2025-11-01 AUTHOR_NAME: Gulzar Hashmi LOCATION: India slug: ananda-expanded-italics

Quick Summary

The court answered a simple question: Can fonts/typefaces get copyright in India? It said no. Section 2(c) lists what counts as an “artistic work.” Fonts do not fit that list. UK law separately mentions “typographical arrangement,” but India’s law does not. So, typefaces are not protected as artistic works.

Fonts ≠ “artistic work” under Section 2(c) in India.
UK’s extra category shows a different approach; India lacks that category.
Designers must rely on other IP tools or contracts.

Issues

Do fonts/typefaces qualify as “artistic works” under Section 2(c) of the Copyright Act, 1957?
If not, can they be registered for copyright protection in India?

Rules

Section 2(c) Artistic Work: The phrase “any other work of artistic craftsmanship” is limited by the specific items in clauses (i) and (ii).
No Typographical Category in India: Unlike UK law, India’s Act does not expressly include “typographical arrangement.”
Resulting Principle: Fonts/typefaces are not artistic works; they cannot be registered for copyright in India.

Facts (Timeline)

Applications Filed

M/s ABP Ltd filed four copyright applications under Section 45(1) as “artistic work” for Bengali alphabet fonts.

Rejection

The Copyright Office rejected the applications, saying fonts are not “artistic works” under Section 2(c).

No Hearing

The applicant was not given a chance to be heard before rejection.

Writ Filed

A writ was filed in the Calcutta High Court challenging the decision.

Order Set Aside for Hearing

The High Court set aside the order to allow a proper hearing—but clarified fonts are not protected as artistic works.

Timeline visual for Ananda Expanded Italics: applications, rejection, writ, and court’s clarification

Arguments

Petitioner (ABP Ltd)

Fonts are artistic creations and should be protected.
The office should have heard the applicant before rejecting.
Public interest supports recognising creative labour in type design.

Respondent (Copyright Office)

Section 2(c) does not list fonts/typefaces.
UK law’s separate “typographical arrangement” shows fonts are different; India lacks such a provision.
Therefore, registration cannot be granted as “artistic work.”

Judgment (Held)

Held: Fonts/typefaces are not “artistic works” under Section 2(c) of the Copyright Act, 1957. The phrase “any other work of artistic craftsmanship” is limited by the specific categories in the section. Since the Indian Act has no separate recognition for typographical arrangement, fonts do not get copyright protection as artistic works. The earlier rejection was set aside only to give the petitioner a hearing.

Judgment imagery for Ananda Expanded Italics: court clarifies fonts are not artistic works

Ratio Decidendi

Section 2(c) must be read narrowly. Without a specific statutory hook (like the UK’s typographical arrangement), fonts cannot be pulled into “artistic work.” Statutory text controls the scope.

Why It Matters

Clarity for creators: Typeface designers in India must plan protection beyond copyright.
Policy signal: Any change would need legislation, not broad reading of Section 2(c).
Market practice: Use licences, trademarks for names, and design protection where eligible.

Key Takeaways

Fonts ≠ artistic works under Section 2(c).
India lacks “typographical arrangement” category.
Registration as artistic work not available.

Consider trademarks for font names.
Consider design protection (if eligible) and contracts.

Mnemonic + 3-Step Hook

Mnemonic: “Font? Not in 2(c).”

Check the Text: Read Section 2(c) list.
Spot the Gap: No “typographical arrangement” in India.
Plan Protection: Use design, TM, and licences.

IRAC Outline

Issue	Whether fonts are “artistic works” under Section 2(c) and can get copyright.
Rule	Section 2(c) is limited to its listed categories; India lacks a typographical arrangement provision.
Application	Fonts do not fall into the listed categories; UK’s broader category is absent in India.
Conclusion	Fonts/typefaces are not protected as artistic works in India.

Glossary

Artistic Work (2)(c): Specific listed categories in India’s Copyright Act; controls what gets protection.
Typographical Arrangement: A UK category for layout/arrangement of published editions; not in India’s Act.
Typeface/Font: Design of letters and symbols used for writing on screen or paper.

FAQs

No. Fonts are not protected as “artistic works” under Section 2(c). Consider other tools like trademark for the font name and contracts for licensing.

Possible options: design registration (if criteria are met), trademark (for name/logo), licensing agreements, and access controls/technology.

To show that the UK does recognise typographical arrangement, which India’s statute does not. This difference supports the court’s conclusion.

Yes. The High Court set aside the rejection to allow a hearing, but clarified that fonts aren’t covered as artistic works.