Copyright concerns sparked in India by alleged leak of ex-Army chief’s unpublished memoir

Copyright concerns sparked in India by alleged leak of ex-Army chief’s unpublished memoir

According to Penguin Random House India (PRHI), the book’s publisher, neither printed nor digital versions of the memoir Four Stars of Destiny have been published, distributed, sold or made available to the public as of February 2026

An unpublished autobiography by former chief of Army staff of the Indian Army, General Manoj Mukund Naravane, is at the eye of an alleged copyright infringement storm in India.

According to Penguin Random House India (PRHI), the book’s publisher, neither printed nor digital versions of the memoir Four Stars of Destiny have been published, distributed, sold or made available to the public as of February 2026.

However, Leader of the Opposition Rahul Gandhi recently acted as if the book had been published. In early February, Gandhi attended a session in Parliament, spoke up and began quoting passages from the unpublished memoir till such time House Speaker Om Birla and others in attendance stopped him. The said passages referred to events on the sidelines of the India-China border clash in the Ladakh region of the western Himalayas in August 2020.

A few days later, Gandhi was seen inside the Parliament complex holding a copy of Four Stars of Destiny and announcing at a press conference that he would personally hand over the copy to Prime Minister Narendra Modi.

A statement issued by PRHI reportedly read: “Any copies of the book currently in circulation, in whole or in part, whether in print, digital, PDF, or any other format, online or offline, on any platform, constitute an infringement of PRHI’s copyright and must immediately be ceased.” The Delhi police are now investigating the incident.

Copyright exists in original literary works upon creation. It is not dependent on a literary work’s publication. Although a work may be unpublished, its manuscript is fully protected under India’s Copyright Act, 1957.

According to Section 17 of the Act, Naravane, as the first owner of copyright subject to any contract of service, would have exclusive rights under Section 14 to reproduce the manuscript, issue copies to the public and communicate the same to the public. If an agreement assigns exclusive publishing rights to the publisher, in this case PRHI, then it would be entitled to exercise and enforce the copyright to the extent of such assignment.

Ridhi Kalra, a principal associate at Krishnamurthy & Co. in Mumbai reportedly said, “Any unauthorized exercise of the rights conferred under Section 14 of the Act in respect of the manuscript would amount to infringement under Section 51 of the Act. Subject to the terms of the publishing agreement, the right holder(s), i.e. the author and/or the publisher, as the case may be, may seek civil remedies under Section 55 of the act, including injunction and damages for infringement of copyright in the manuscript. Where the infringement is wilful, the right holder(s) may also invoke criminal remedies under Section 63 of the act. In addition, the author retains independent moral rights under Section 57 of the act, including the right to restrain acts prejudicial to his honour or reputation and to demand cessation of unauthorized distribution.”

This also raised questions from a contractual standpoint.

Kalra reportedly explained, “This case highlights the importance of monitoring leaks and embedding robust confidentiality and enforcement mechanisms in contracts within publishing agreements and with third-party stakeholders, including security safeguards, ensuring strong indemnity clauses and enforcement rights, and clearly defined remedies in case of premature disclosure of the works.”