Copyright explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Part 4 of the Cinematograph Films Manual lists eleven issues the Office has seen in day-to-day examination, with the answer to each. Some tell the Office not to write a discrepancy letter, which is just as useful to know. The rule behind most of them is rule 70, explained in our post on rule 70.
Status. The Manual was published by the Copyright Office in 2018 after public comments on a draft. It is the Copyright Office's guidance and does not have the force of law; the Copyright Act, 1957 and the Copyright Rules, 2013 as now in force prevail. The Office may revise its practice, so check the current position on copyright.gov.in.
Eleven issues recur. A letter is the expected result where several videos are filed on one application and fee, where the consideration amount is blacked out, where the title does not match, where a photocopy stands in for an agreement without notarisation, and where a script is filed as a film. A letter should not issue for a missing Statement of Further Particulars or for NOCs from persons only named in Columns 11 and 12. Use our objection reply service if one arrives.
The eleven issues, in a table
| Issue | What the Office does | What to do |
|---|---|---|
| 1. Several videos on one CD or drive | If separate fees and separate applications were filed, different videos on one drive are acceptable and no letter should issue. If one application and one fee cover all, a letter says only one video can be registered, and asks for a fresh copy of the one chosen | File one application per video; a shared drive is fine if each has its own application and fee |
| 2. Statement of Further Particulars | Not required for films; no letter should issue if it is missing, unfilled or incomplete | Leave it out, or do not worry if the printout is blank |
| 3. Consideration amount blacked out | Not acceptable; section 19(3) needs the amount shown | File the agreement with the consideration visible |
| 4. Applicant is the sole creator | Affidavit that the applicant is the sole creator and no other person holds rights; original or notarised | File the affidavit |
| 5. Title mismatch | Title in Column 5 must match the title on the work; on the CD cover, the CD itself or in the film is acceptable. A letter issues if no title appears or it is quite different | Copy the title as shown |
| 6. Photocopies of agreements | Originals, or notarised copies, with the application; where the same terms apply to many works, original notarised copies of the same agreement are acceptable | File originals or notarised copies |
| 7. Script or screenplay filed as a film | Considered only in the literary category | File the script as a literary work |
| 8. Person's photograph on the CD or cover | No NOC needed if that person holds no rights in the work, because the copyright claimed is in the audio-visual content | No NOC for the picture alone |
| 9. Column 12 | Optional; names, addresses and nationalities of those the applicant authorises to assign or license, apart from those in Column 11 | Fill if relevant |
| 10. NOC from persons named in Columns 11 and 12 | Not needed; section 14 gives the owner the right to grant authority, so no clarification or NOC is asked | Do not attach |
| 11. Names of films | Names and titles are not subject to copyright registration | Do not file a title alone |
What drives most letters
Three themes explain most of the table.
One work, one application. The Manual relies on rule 70(2) and on the definition of "work" in section 2(y) as "a" cinematograph film. The disc is only a carrier. Our guide on digital content creators is useful for people with many clips, because each clip that is a distinct film needs its own application.
Complete paper. A blacked-out amount, a photocopy and a missing affidavit all arise from incomplete documents. The Manual says the agreement must show the amount, and it permits original notarised copies of an identical agreement across several works.
Match the form to the work. A title that differs from what appears on the work, or a script filed as a film, makes the file inconsistent.
What the Office does not need
Items 2, 8 and 10 are where the Manual says no letter should go. An applicant who receives a letter on one of them can point to the Manual's own position. Attach the Manual reference and keep the reply to a single paragraph. Remember that the Manual is guidance; the Act and the Rules as now in force prevail, so rely on the Manual as persuasive, not binding.
How to answer a discrepancy letter
- Read the exact ground. The letter names the shortcoming.
- Match it to the issue. If it is one of the "should not" points, say so briefly.
- File the cure in the form the Manual describes. Original or notarised copies of agreements, an original or notarised affidavit, a fresh single-work copy.
- Do not volunteer extra documents. More paper rarely helps where a single missing item is the cause.
The Manual gives no reply period; check the letter itself for any time limit.
A worked example
Nikhil Arora files one application and one fee for a flash drive holding four short films. The examiner writes that only one video can be registered against one fee and diary number and asks for a fresh copy of the film to be registered. Nikhil chooses his most recent film; a better course would have been four applications, four fees, and one shared drive. His agreement with the music composer has the consideration blacked out, and that draws a second point in the same letter.
Need help with a film copyright letter?
We can map each point in the letter to the Manual's issue, prepare the corrected papers and draft the reply through our copyright objection reply service.
Key takeaways
- One application and one fee per video; the drive is only a carrier.
- Show the consideration amount in agreements; file originals or notarised copies.
- Statement of Further Particulars is not needed; NOCs for Column 11 and 12 names are not needed.
- Script or screenplay belongs to the literary category.
- Names and titles of films cannot be registered.
Read next
- The five Copyright Office manuals and how an application is examined
- Cinematograph Films Manual: definition, publication, NOCs and agreements
- Sound Recordings Manual: commonly observed issues
- Literary Works Manual: non-copyrightable subject matter
Disclaimer: Based on the Practice and Procedure Manuals published by the Copyright Office in 2018 for literary, artistic, musical, cinematograph film and sound recording works, as consulted on 4 October 2026. The manuals are guidance and do not have the force of law; the Copyright Act, 1957 and the Copyright Rules, 2013 as now in force prevail, and current fees, forms and practice should be checked on copyright.gov.in. This article is general information, not legal advice; check the official text before acting.