by Sadie Ovenden
When Cord released its Album ‘91 SS’26 campaign, internet commentary quickly observed that, with its symmetrical framing and saturated vintage colour palette, it resembled a scene from Wes Anderson’s The Darjeeling Limited (2007). Cord describes the collection as an ode to childhood summer holidays in India, to train journeys, family travel, vibrant markets, festive colours and traditional craft practices. The collection draws explicitly upon Indian visual culture, through hand embroidery, appliqué, smocking and patchwork alongside bright colour palettes intended to highlight the textures and rhythms of Indian summers. Yet public discussion did not read these references principally through the lens of Indian design traditions. Instead, they were understood through the aesthetic language associated with Anderson. The discussion raises a broader question that extends beyond advertising aesthetics. Who, if anyone, owns artistic style?
This question may be approached from a range of perspectives, including cultural, historical, economic and legal. For present purposes, however, it is useful to distinguish between two related but distinct inquiries. The first concerns attribution and recognition. It asks who should be credited for developing a particular visual language, how artistic influence ought to be acknowledged, and whether histories of borrowing can obscure earlier creators or broader traditions. Anderson has repeatedly acknowledged the influence of Bengali filmmaker Satyajit Ray on his work. The Darjeeling Limited was dedicated to Ray, incorporates music associated with Ray’s films, and Anderson has described Ray as one of his most significant artistic influences. What has been identified as the “Wes Anderson style” may therefore itself be indebted, at least in part, to Indian cinematic and artistic traditions. From this perspective, the relevant question is not simply whether Album 91 borrows from Wes Anderson, but whether it engages with visual traditions that Anderson himself adapted and popularised for global audiences. The second concerns legal entitlement. A creator may deserve recognition for shaping a particular style without possessing an enforceable legal right over its subsequent use. Copyright law is not primarily concerned with tracing histories of influence or identifying the origins of a visual language. Rather, it asks whether the expression at issue constitutes protectable subject matter. Even if one accepts that Ray played an important role in shaping aspects of a visual language now associated with Anderson, it does not follow that either creator possesses a legal right to prevent others from employing comparable stylistic features. The legal inquiry is therefore narrower.
Section 13 of the Copyright Act 1957 recognises copyright in literary, dramatic, musical and artistic works, cinematograph films and sound recordings, but nowhere identifies style as an independent category of protectable subject matter. In the case of cinematograph films, section 2(d)(v) provides that the author is the producer, defined in section 2(uu) as the person who takes the initiative and responsibility for making the work. Indian copyright law therefore protects films as completed works, but does not expressly recognise a director’s distinctive visual language as an object of copyright in itself.
The principal obstacle to recognising copyright in style is the idea-expression distinction. Although not expressly codified in the Copyright Act 1957, Indian courts have consistently held that copyright protects the expression of ideas rather than ideas themselves. The leading authority remains R.G. Anand v Deluxe Films (1978), in which the Supreme Court held that there can be no copyright in “ideas, subject matter, themes, plots or historical facts”, but only in the manner in which those ideas are expressed. Similarities arising from the use of common themes or concepts do not amount to infringement unless there has been substantial appropriation of expression. Applied to style, R.G. Anand suggests that recurring artistic choices are analogous to themes, techniques or methods, which copyright deliberately leaves in the public domain. Symmetry, colour palettes, editing, composition and production design may become strongly associated with a particular filmmaker, but they are difficult to characterise as the expression embodied in any single work. Instead, they function as a visual language, rather than a copyrightable expression.
At the same time, Indian copyright law has evolved beyond a labour-based idea of authorship. In Eastern Book Company v D.B. Modak (2008), the Supreme Court adopted a standard requiring a “modicum of creativity”, rejecting the traditional “sweat of the brow” approach. The decision recognises that originality may reside in creative selection, coordination and arrangement, leaving open the possibility that a highly specific arrangement of aesthetic choices in film might constitute original expression. Nevertheless, D.B. Modak does not displace the idea-expression distinction articulated in R.G. Anand. More recent disputes illustrate the continuing force of this distinction. The litigation between Humans of Bombay v. People of India debate centred on the extent to which narrative formats, visual presentation and modes of storytelling may attract copyright protection. Although the proceedings did not concern artistic style directly, they reaffirmed the principle that copyright protects the particular expression of a work rather than broader concepts, formats or creative approaches. Indian law therefore provides no clear answer as to whether a sufficiently distinctive and consistently used visual language could be protected as expression. Therefore, s court faced with the claim that an advertising campaign, film or AI-generated image reproduces the “style” of a filmmaker would have to decide whether style is best understood as a technique or method that remains available to all, or as a sufficiently concrete arrangement of expressive elements deserving protection. Existing doctrine strongly favours the former position. Yet the growing commercial value of artistic style may eventually require courts to reconsider whether copyright’s traditional categories adequately address contemporary forms of authorship.
The reaction to Cord’s Album ‘91 SS’26 campaign therefore highlights a question that Indian copyright law has yet to answer: at what point do recurring aesthetic choices become sufficiently precise, distinctive and consistent to move beyond technique and become protectable expression? The issue has become particularly pressing in the age of Artificial Intelligence. Generative systems can now produce images, films and texts “in the style of” particular creators with mathematical precision. Determining whether style remains part of the cultural commons, or whether it may eventually constitute an actionable right, is an issue ripe for judicial consideration.
References:
Album 91 SS’26 Collection, Cord Studio https://www.cordstudio.com/collections/album-91-ss26?srsltid=AfmBOooDGYyZhAJkV21oZHX6CGVT9idSdz6Ld84YNjlmOkUC-wCU3tFV
The Copyright Act, 1957 (India)
Payal Khandelwal, ‘Cord studio on using symmetry and cinema to create one of 2026’s most viral campaigns’ https://www.itsnicethat.com/features/cord-studio-creative-industry-advertising-spotlight-290626
Anupama Chopra, Wes Anderson Shares How Indian Cinema Legend Satyajit Ray Shaped His Aesthetic, The Hollywood Reporter (5 June 2025)
Christopher Buccafusco, ‘Copyrighting Style’ 72 Journal of Copyright Society (2025) 1091-1130.
R.G. Anand v Deluxe Films (AIR 1878 SC 1613)
Eastern Book Company v D.B. Modak 2008 (1) SCC 1
Humans of Bombay v. People of India (11 October 2023) CS(COMM) 646/2023 & I.A. 18038/2023 & I.A. 20079/2023