An unpublished autobiography by General Manoj Mukund Naravane, former chief of army staff of the Indian Army, is at the centre of an alleged copyright infringement incident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

According to the book’s publisher, Penguin Random House India (PRHI), 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, opposition leader Rahul Gandhi acted recently 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 In early February, Gandhi attended a session in Parliament, spoke up and began quoting passages from the unpublished memoir until House Speaker Om Birla and others in attendance stopped him.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 in the Western Himalayas in August 2020.

After a few days, 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.

“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 statement by PRHI read as reported by the Deccan Herald.

The incident is now being investigated by the Delhi Police.

Copyright subsists 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 Although a work may be unpublished, its manuscript is fully protected under India’s Copyright Act, 1957.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.

“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 willful, 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,” said Ridhi Kalra, a principal associate at Krishnamurthy & Co. in Mumbai.

The incident also raises questions from a contractual standpoint.

“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,” Kalra explained.

- Espie Angelica A. de Leon