Artificial Intelligence and the Evolving Landscape of Intellectual Property Law
Published: Jan 28, 2025
By Shweta Gupta, LLB, CS
IN our fast-evolving world, the intersection of artificial intelligence (AI) and intellectual property (IP) laws has become a crucial and contentious issue. As AI systems push the boundaries of creativity by producing content ranging from literature to scientific breakthroughs, they challenge traditional IP frameworks in profound ways.
Traditionally, IP laws are built around concepts like originality, the "sweat of the brow" theory, and human innovation and ownership. AI complicates these notions in several key ways. For instance, AI often generates content by analyzing vast amounts of existing data, which raises questions about what constitutes true originality. The "sweat of the brow" doctrine, which emphasizes the human effort behind a creation, seems less relevant when AI produces work with minimal human input. Moreover, the rapid and iterative nature of AI's creative process makes it difficult to assess novelty in the traditional sense.
As AI takes on roles previously reserved for human creators, traditional IP laws-designed to attribute rights to human authors and inventors-find themselves struggling to address the complexities of AI-driven creation. This ambiguity challenges established notions of authorship and ownership and has significant implications for various forms of IP, including trade secrets, copyrights, patents, and trademarks.
To navigate this shifting landscape, we might need to rethink our legal frameworks or create new ones altogether. This could involve revising how assignment and licensing rights are handled, which could, in turn, complicate IP transactions and agreements. The aim would be to develop approaches that adequately recognize and protect AI's contributions without undermining human creators' rights.
Imagine a world where AI creates art using invisible brushstrokes or composes music with the flair of Mozart. In this digital renaissance, a pressing question emerges: should these AI- generated works receive copyright protection? The rapid advancement in IP technology has opened new avenues for legal professionals to focus on strategic challenges and enhance productivity. However, it also highlights the need to reassess our current IP systems.
AI's transformative impact on IP underscores the necessity for reform. For instance, if an AI system invents something ground breaking, who should receive the credit? Should it be the AI itself, or the individual who developed the AI? The legal system must address these questions, as current frameworks often fall short in accommodating these new realities.
AI's influence extends across various IP domains, including trade secrets, patents, trademarks, and copyrights. While AI offers significant advantages, such as efficient data processing and legal research, it also presents challenges related to authorship and ownership. This article explores how AI affects IP rights and the difficulties involved in protecting these rights.
AI has revolutionized the way we work, and its impact on intellectual property is profound. With AI capable of creating original works through advanced reasoning, machine learning, and linguistic intelligence, the landscape of IP is shifting. AI-driven algorithms enhance the efficiency of searching IP databases and examining technical documents to prevent copyright infringement. As AI technology continues to evolve, new legal challenges will inevitably arise.
Consider the analogy of a chess game. Just as a chess player must anticipate and counter their opponent's moves, IP laws must adapt to the advancing capabilities of AI. Every legislative decision or technological development must be carefully considered and strategically planned. The goal is to create a legal framework that fosters AI-driven innovation while also protecting the rights of human creators.
1. Copyright
1.1 Copyright and AI Indian Perspective
Originality
Perceived lack of originality is one of the main arguments opposing copyright protection for AI- generated works. Opponents claim that because these AI systems are incapable of thinking for themselves, the results they generate are just mashups of already-existing material that they found online. As a result, it's argued that AI-generated works don't satisfy India's "originality" requirement for copyright protection.
In the seminal Eastern Book Company v. D.B. Modak case1, It was the Indian Supreme Court that set the current standard for determining "originality." The Supreme Court decisions from the Supreme Court Cases (SCC) monthly published by Eastern Book Company (EBC) were included into software created by developers who were sued for copyright infringement. First, the developers argued that since judicial rulings are akin to official government documents and are not copyright protected, the SCC does not have copyright over them. The Supreme Court of India deliberated on multiple interpretations of "originality."
It disapproved of the "Sweat of the Brow" idea as being too lighthearted and the American "modicum of creativity" standard as being too strict. Instead, it embraced the Canadian standard, which states that a written work should demonstrate the author's skill and judgment rather than being merely a mechanical exercise. The court affirmed the SCC's view that the judgments were copyrightable, noting that EBC added elements such as paragraph numbers, headnotes, and cross-references using legal knowledge and discernment. This interpretation puts into doubt the assertion that AI-generated works lack originality because they rely too heavily on pre- existing data. The Indian meaning of "originality" emphasizes the creator's use of expertise and judgment over necessity. Because of this, AI-generated works may satisfy the "originality" criteria under copyright law in India, even if they are derived from previously published works.
Raghav Copyright Case
In processing the copyright protection application, the Indian copyright office mistook the AI system RAGHAV for a co-author of a creative work. The copyright office first rejected the application filed by RAGHAV's designer, Ankit Sahni, citing the AI system as the only author. After acknowledging the administrative error and notifying Mr. Sahni, the human co-author, to cancel the registration, the copyright office caused him to reassess the legal standing of the AI system RAGHAV. However, while the case is awaiting a court decision, the application remains labeled as "registered" on the copyright office's website.
The court's ruling will have significant effects on worries regarding AI systems and Indian laws pertaining to intellectual property copyright protection. It is expected to set a standard for future occurrences of this kind given the continuous improvements in the complexity and powers of AI systems.
B. Human Creativity Standard
Human authorship is a requirement for copyright protection, according to the Copyright Act. The requirement for human involvement becomes crucial in Indian copyright law in cases where AI plays a significant role in creating a work, as demonstrated in cases such as Navigators Logistics Ltd. v. Kashif Qureshi2, where a copyright claim for a computer-generated list was rejected due to minimal human intervention.
Legal precedents provide two fundamental requirements-the "Significant Input" test-that determine eligibility for copyright when AI assistance is applied. It assesses whether or not human intervention took taken at any point during the creation process. Secondly, it evaluates the amount of human contribution, asking if it was significant enough to guarantee that the task could not have been completed without it or if it was insufficient to make a significant impact.
To illustrate this point, let's examine a scenario in legal academics where an author uses artificial intelligence (AI) technologies to swiftly compose a legal commentary by synthesizing academic works and court opinions. AI assists in improving language and structure, but the author is still responsible for conducting in- depth research, producing the content, and providing perceptive analysis. Here, the writer meets the two criteria of the Significant Input test: there is a substantial human involvement throughout the creative process, and the human contribution is necessary for the creation and quality of the end product. Even with the help of AI, this is true. Given the significant human engagement and consequent impact on the creation and content of the work, the author would thus be eligible to claim copyright over the remark under Indian copyright law.
1.2 Copy Right and AI - International Perspective
A. USA
Artificial intelligence (AI) and copyright law in the United States have a complicated and developing interaction. According to current U.S. copyright laws, a work must be original and written by a human author in order to be protected. This requirement has spurred discussions over whether AI-only works can be protected by copyright as AI isn't currently recognized by law as a legitimate creator. But if a human creator uses AI as a tool, the finished product may be protected by copyright as long as the human creator made a significant creative input. In these situations, the copyright usually belongs to the person who oversees and uses the AI, indicating their participation in the creative process.
These issues are being aggressively addressed by legislative and policy initiatives. In response to developments in AI technology, Congress has been debating and proposing updates to copyright laws, including matters like AI authorship and copyright ownership. Several parties, including IT firms, authors, and legal professionals, are debating the best ways to strike a balance between fostering innovation and safeguarding intellectual property. Furthermore, global viewpoints show that many nations are treating AI and copyright in different ways, which may have an impact on legislative reforms in the United States.
Case law
The United States established a precedent in the Zarya case, when a graphic novel composed solely of artificial intelligence- generated graphics was safeguarded by the Copyright Office. This decision was based on how successfully the human author was able to select, arrange, and edit the AI-generated content in a way that made sense for a graphic novel. The US Copyright Office subsequently published a regulation indicating that AI-generated works might qualify for copyright if they show a significant level of human authorship.
In practical terms, the Zarya standard emphasizes the author's unique content arrangements and choices, which are critical for demonstrating originality within the framework of a graphic novel. On the other hand, human creativity as it manifests in significant engagement in the creative process-which may extend beyond specific tasks like organizing and selecting-is honoured by the Significant Input test.
Moreover, the suggested test in India rejects the US "modicum of creativity" standard, arguing that it is too stringent for copyright laws. Instead, it more closely aligns with the objectives of Indian copyright law with the Canadian "Skill and Judgment" standard. By ensuring that AI-generated works that meet the standards of human creativity and effort can be eligible for copyright protection in India, this policy facilitates a more smooth transition into an era where AI-driven inventions become the norm.
B. UK Perspective
The relationship between copyright law and artificial intelligence (AI) in the UK is changing as AI technology is incorporated into creative processes more frequently. At the moment, copyright protection is only granted to works authored by humans, according to UK copyright law, which is regulated by the Copyright, Designs and Patents Act 1988 (CDPA). Therefore, under the current paradigm, works produced entirely by AI without a substantial amount of human interaction are not eligible for copyright protection. The need for human authorship has made it difficult to assess whether AI-generated works are protected by copyright. However, the resulting work can be protected by copyright, with the human author being identified as the copyright holder, if the human employs AI as a tool and makes a significant creative contribution.
Case law
The case of "Football Association Premier League Ltd v. QC Leisure" (2011) highlighted the necessity of providing precise legal interpretations on copyright in relation to technological advancements. Similar to this, the 2017 decision "Authors' Licensing and Collecting Society Ltd (ALCS) v. The Publishers Association" addressed licensing of digital work and established a standard for handling copyright challenges in the digital era. While primarily addressing patent law, the "Schütz v. Werit" case (2020) also addressed concerns pertaining to technological improvements and intellectual property rights, highlighting the larger legal framework affecting copyright and artificial intelligence.
2. PATENT
2.1 Patent and AI - Indian Perspective
The nexus between patent law and artificial intelligence (AI) has generated heated debates and important legal issues in recent years. AI technologies are being used more and more to generate inventions and innovations in a variety of industries as they develop. This begs the fundamental question of how AI-generated inventions are subject to patent law, which is generally crafted with human inventors in mind.
At the heart of the issue is the concept of inventorship. Patent laws typically require an inventor to be a natural person who conceives of the invention. However, with AI systems capable of autonomously generating inventive concepts and solutions, the determination of inventorship becomes blurred. The United States Patent and Trademark Office (USPTO) has addressed this issue by clarifying that AI- assisted inventions can be patented if they involve significant contribution from a natural person. This means that while AI can be a tool for innovation, it cannot replace the legal requirement for human inventorship.
Furthermore, the quick development of AI presents special difficulties for patent law that go beyond inventorship. Artificial Intelligence (AI) has the potential to revolutionize the processing and evaluation of patent applications by improving the speed and accuracy of patent searches and analysis. But they also bring with them complications over who owns AI-generated ideas, who is liable for infringement, and how this may affect customary patent review processes.
The Delhi High Court held in Gaurav Bhatia v. Union of India that AI-generated inventions could be eligible for patent protection provided they satisfied the Patents Act's requirements for novelty, non-obviousness, and industrial application.
Case laws
The Bombay High Court ruled in Nippon Steel Corporation v. Union of India that computer programs that generate inventions or discoveries cannot be protected since they cannot be produced by a human.
The Indian Patent Office denied a drug discovery algorithm patent application in Re: Sugen Life Sciences Pvt. Ltd, stating that the algorithm was a computer program and hence not patentable under Section 3(k) of the Patents Act.
In Dr. Alaka Sharma v. Union of India, the Delhi High Court held that an AI-generated portrait did not meet the distinctiveness requirement for registration as a trademark under the Trademarks Act.
In My Space Inc. v. Super Cassettes Industries Ltd., the Delhi High Court concluded that an AI-based algorithm used for identifying and removing infringing content on a social media platform did not violate the Copyright Act since it did not involve the reproduction of copyrighted content.
2.2 Patent and AI International perspective
A. United States
New, non-obvious, and practical inventions may be granted a patent in the United States under the Patent Act. But the U.S. Patent and Trademark Office (USPTO) has released guidelines that primarily deal with inventions connected to artificial intelligence (AI), with a particular emphasis on whether the inventions incorporate a significant amount of human participation.
Case laws
Alice Corp. v. CLS Bank International Case Laws (2014): This important Supreme Court ruling made it clearer what constitutes patentable subject matter under Section 101 of the Patent Act, highlighting the fact that abstract concepts-which includes some software and business practices-do not qualify for patent protection unless they contain an original idea. AI-related patents are affected by this case, especially those that deal with abstract algorithms or data processing techniques.
In the 2021 lawsuit Thaler v. Hirshfeld, the inventor mentioned was an artificial intelligence system called "DABUS." The Federal Circuit upheld the requirement that patents have human inventors by ruling that an AI cannot be regarded as an inventor under US patent law. This choice affects the attribution of AI-driven inventions.
B. European Union
The European Patent Community (EPC) establishes the legal foundation for patenting in Europe, mandating that innovations be novel, incorporate an innovative step, and have potential for industrial use. In its rules, the European Patent Office (EPO) has addressed artificial intelligence (AI) and emphasized that inventions pertaining to AI must be technical in nature, solving a technological problem.
Case laws
EP 2771468" 2019: The EPO's Technical Board of Appeal ruled that a patent application involving AI and a method for improving an existing process was eligible for patent protection, provided it demonstrated a technical effect or solved a technical problem. This case reinforced the EPO's approach to AI-related inventions requiring technical contributions.
Dabus case
A number of nations, including Australia, the United Kingdom, the United States, New Zealand, and the European Patent Office, rejected ideas created by Stephen Thaler's AI system, Device for the Autonomous Bootstrapping of Unified Sentience (DABUS), for patent. These nations cite their patent regulations, which stipulate that an inventor may only be acknowledged as a natural person in a patent application. However, the DABUS case has heralded a significant shift in both patent law and artificial intelligence. The patenting of concepts attributable to DABUS was made possible by the approval of Stephen Thaler's application under the Patent Cooperation Treaty by the South African Companies and Intellectual Property Commission (CIPC) on June 24, 2021. This was a crucial step. DABUS is the first artificial intelligence system to be officially recognized as an inventor and granted a patent for its discoveries thanks to this landmark decision from the CIPC.
C. Australia
Australian patent law likewise needs human inventors, as per the Patents Act 1990. Based on current criteria, the Australian Patent Office has evaluated patents pertaining to artificial intelligence, emphasizing innovative steps and technical achievements.
Thaler v. Commissioner of Patents Case Laws (2021): The Australian Federal Court decided in this instance that AI is not considered an inventor under Australian law. The ruling has an impact on how AI-driven discoveries are handled because it is consistent with the idea that patent law requires human inventors.
3. TRADEMARK
3.1 Trademark and AI Indian perspective
The incorporation of AI creates a dual picture of potential and difficulties in the field of trademark law. Trademarks have historically been associated with companies or individuals that use them to set their goods and services apart from competitors. However, AI systems are usually not considered autonomous trademark owners; rather, they are tools developed and managed by these businesses. AI has a wide range of applications in trademark administration. By utilizing its capacity to handle enormous volumes of data, it can improve productivity in jobs like looking for conflicting marks, keeping an eye on trademark usage, and evaluating portfolios. However, even with AI support, judgments about trademark distinctiveness and probability of confusion are still based on legal standards applied by human assessors.
Trademarks need to be regularly used in the marketplace in order to be valid and enforceable. The growing use of AI in digital transactions and e-commerce has ramifications for the protection and enforcement of trademarks in these contexts. Legal issues are also quite important, especially when it comes to responsibility and liability for choices made or actions conducted by AI systems in relation to trademarks. In order to shape the changing field of trademark law, courts may need to define the obligations of AI developers, users, and owners in disputes.
Case laws
The Delhi High Court rendered a decision in the M/S Kibow Biotech v. M/S An artificial intelligence (AI) system cannot be identified as the proprietor of a trademark, according to the Registrar of Trade Marks. The court decided that only a natural person may file an application for and be registered as the owner of a trademark in accordance with the Trade Marks Act of 1999. The Act's provisions do not grant AI systems the status of persons.
3.2 Trademark and AI International Perspective
A. US
The framework for trademark registration and protection is provided by the Lanham Act, which is the cornerstone of trademark law in the United States. Trademarks must meet certain requirements under this Act in order to be eligible for registration. A crucial prerequisite is that the trademark ought to be distinctive, which implies it should be able to recognize and set one party's products or services apart from others. A spectrum is used to evaluate distinctiveness; arbitrary or fantastical marks receive the greatest degree of protection, whereas descriptive marks receive less protection unless they have become distinctive via repeated use. A trademark must also be actively used in commerce to show that it is being used in the exchange of goods or services in order for it to be registered. This stipulation guarantees that the trademark is more than just an abstract notion; rather, it has a real existence in the market. In addition, the Lanham Act describes the processes for filing, reviewing, opposing, and enforcing trademarks with the goals of preventing consumer confusion and safeguarding trademark holders' rights. As a result, the Act has a significant influence on how trademarks are created, preserved, and defended in the United States, helping to guarantee that they adhere to the legal requirements for distinctiveness and economic use.
Case Laws
In 2020, the U.S. Supreme Court decided in the case of "In re Booking.com" that, despite being a generic term coupled with a generic top-level domain (gTLD), "Booking.com" could be registered as a trademark. This case demonstrates how courts appraise a mark's distinctiveness, which may have an effect on the consideration given to AI-generated names or phrases when registering a trademark.
Google LLC v. Oracle America, Inc." (2021) While mostly pertaining to copyright, this case also touches on technological and software- related issues, which can affect trademark considerations in AI contexts, particularly with relation to software and branding.
B. European Union
Trade Mark Regulation of the European Union (EUTMR): The registration and protection of trademarks in all EU member states are governed by this legislation. Trademarks cannot be descriptive or deceptive; they must be unique.
Sky v. Skykick (2020): The legality of trademarks that were registered with excessively general descriptions of products and services was related patents, especially those containing ab stract algorithms or data processing technique s, may be affected by this case.
On the validity of trademarks that were registered with unduly general descriptions of products and services, the Court of Justice of the European Union (CJEU) rendered a decision. This decision is significant because it could have an impact on the way that trademarks pertaining to artificial intelligence- which has many potential uses-are evaluated for their validity and specificity.
EUIPO's Resolution Regarding AI-Generated Trademarks(2021): The European Union Intellectual Property Office (EUIPO) has reviewed applications in which artificial intelligence (AI) was used to create trademarks. Although the EUIPO demands human application submissions, the ruling illustrates how AI-generated information is considered during the trademark registration procedure.
4. Legal Challenges
Navigating global IP laws poses significant challenges for AI developers due to differing standards across countries. Efforts to harmonize these standards, such as through the TRIPS (Trade-Related Aspects of Intellectual Property Rights) agreement, face obstacles due to national regulatory differences. Cross-border enforcement of IP rights remains complex, particularly in digital spaces where proving infringement can be costly and complicated.
The challenge of protecting intellectual property rights for AI technologies is multiplied. It takes specialist knowledge to identify and prove infringement, particularly with regard to intangible assets like trade secrets or software patents. Accessible dispute resolution processes like mediation and arbitration are crucial since smaller firms are frequently discouraged from defending their intellectual property due to the high expenses and drawn- out litigation.
A diverse approach is necessary to address the ethical and legal concerns related to AI and intellectual property. Ethically, building trust and reducing biases requires advancing justice, accountability, and openness. Legally speaking, preserving innovation while guaranteeing equitable access to IP protections depends on bringing international IP norms into line and strengthening enforcement systems. Stakeholders must continue to collaborate as AI develops in order to strike a balance between innovation and international legal and ethical protections.
5. Future Aspects
To meet new challenges, the changing IP and AI ecosystem necessitates aggressive legal revisions. Revision of copyright laws to include AI-generated works and the recognition of AI as a co-inventor in patent laws are important areas for reform. This will make it clear that humans are involved in the creative process while also ensuring that AI innovations receive the proper protection.
To harmonize IP rules across national borders, international cooperation is necessary. Cross- border IP enforcement for AI technologies can be facilitated by working with bodies like WIPO and strengthening agreements like TRIPS. These actions can also offer uniform standards.
Stakeholders ought to concentrate on creating thorough regulatory frameworks that strike a balance between protection and innovation. Legislators ought to enact rules that uphold moral behavior while encouraging AI development. Researchers should place a high priority on explainable AI and fairness, while businesses need to implement strong IP strategies that incorporate bias prevention and transparency.
The US National AI Initiative Act, the EU's AI Act, and India's AI plan are examples of recent international initiatives that attempt to incorporate AI developments into legal frameworks.
In conclusion, adaptable legal frameworks, global collaboration, and best practices from all stakeholders are essential to the future of AI and IP protection. In a fast changing technological context, responsible AI development and strong IP protection will be ensured by embracing innovation and addressing ethical and legal challenges.
6. Leading Companies Efforts to Manage AI and IPR
Prominent technology corporations such as IBM, Google, Microsoft, and Tencent are leading the way in incorporating artificial intelligence (AI) into their strategies for managing intellectual property rights (IPRs).
AI is widely used by IBM in IP administration, including portfolio management and patent searches. The company publishes ethical principles for AI development and deployment and possesses multiple patents related to AI. It also places a strong emphasis on accountability and openness.
Google uses artificial intelligence (AI) in a number of ways, from content creation to search algorithm improvement. It actively patents its AI inventions and makes use of AI technologies for IP enforcement and monitoring. Google works with international groups to develop global IP regulations and focuses on avoiding AI bias through stringent internal evaluations.
Microsoft uses technologies for copyright enforcement, trademark monitoring, and patent analytics to incorporate AI into its IP management. Microsoft, which has a sizable portfolio of AI patents, participates in policy debates and places a high value on fairness and explainability in AI systems.
Leading Chinese tech company Tencent creates content with AI and oversees a vast intellectual property portfolio. It emphasizes innovation and careful intellectual property management, and it closely complies with Chinese rules to guarantee robust protection for its AI technologies. To sum up, these businesses show how AI is changing IPR administration. Their methods highlight the necessity of modifying legal frameworks to take ethical and technical developments into account. In order to navigate complexity and ensure ethical AI use, industry stakeholders, regulators, and international authorities must continue to collaborate as AI advances.
7. Legal Actions Against AI Companies for Copyright Violations
As artificial intelligence (AI) continues to evolve and revolutionize industries, the ethical and legal implications of its development have come under increased scrutiny. A growing number of lawsuits have been filed against AI companies for allegedly violating copyright laws while training their models. This article explores some of the most significant cases, the legal challenges they pose, and the broader implications for the future of intellectual property rights in the AI era.
The Growing Concern Over Copyright Violations
AI models, especially those that rely on deep learning techniques, require vast amounts of data to function effectively. Often, this data is sourced from publicly available content, including copyrighted works such as books, images, music, and more. The use of these materials without explicit permission has sparked legal battles and raised ethical concerns about intellectual property infringement.
Key Legal Actions Against AI Companies
1. Authors Guild v. OpenAI
In a landmark case, the Authors Guild sued OpenAI for allegedly using copyrighted literary works to train its language models without obtaining proper licenses. The lawsuit claims that this practice undermines the value of creative content and threatens the livelihood of authors by enabling the generation of derivative works.
2. Getty Images v. Stability AI
Getty Images filed a lawsuit against Stability AI, accusing the company of scraping its copyrighted images from the internet to train its AI models. According to Getty Images, the unauthorized use of its premium content not only violates copyright laws but also impacts its business model by devaluing its intellectual property.
3. Composers v. Google
A group of composers brought a case against Google, alleging that the tech giant used copyrighted music compositions to train its AI- driven music generation tools without securing proper licenses. The plaintiffs argue that such practices could diminish the originality and economic value of their creative works.
Implications for the AI Industry and IP Law These legal cases highlight the urgent need for clearer guidelines and regulations governing the use of copyrighted materials in AI training. They also underscore the importance of balancing innovation with respect for intellectual property rights. Failure to address these issues could lead to more legal disputes, stifle creativity, and hinder technological progress.
Conclusion
In conclusion, there are significant implications and a dynamic and complex environment around the integration of artificial intelligence (AI) into intellectual property (IP) rules. Along with notable advances in innovation, automation, and efficiency across a variety of IP domains, such as trade secrets, copyrights, patents, and trademarks, AI also poses unique obstacles.
Important issues include figuring out authorship and inventorship rights, applying established legal precedents to AI-generated works, and how these issues may affect accountability and culpability. Courts and regulatory bodies throughout the world are trying to find a middle ground between promoting innovation and ensuring fair and effective protection of intellectual property rights.
Future IP law improvements may be required to support AI developments, in addition to greater international collaboration. To strike a balance between intellectual property protection and innovation, policymakers, companies, and researchers must work together. It is crucial to address the nexus between AI and IPR in order to promote creativity and innovation.
AI will transform industries and intellectual property policies as it develops, highlighting the necessity of ongoing cooperation and adaptation. In this ever-changing environment, the quest of accountability and justice will determine the course of intellectual property in an AI-driven society where ethics and technology intersect to influence our collective growth.
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1 https://indiankanoon.org/doc/1062099/
