In Fortune Films v Dev Anand the Court had to decide whether an artiste's work in the film would be entitled to protection as falling within the definition of a "work" protected by copyright. It was observed by the Court that the artiste's performance does not constitute either an artistic work or a dramatic work as conceptualized under the Act. The Act does not recognize the performance of an actor as constituting a 'work' which is subject to protection under the Copyright Act.