Section 13(1)(a) of the Indian Copyright Act, 1957 mentions 'originality' as a requirement for copyright protection to literary, dramatic, musical and artistic works. Courts have interpreted this requirement of 'originality' in different ways. This has given rise to various doctrines/tests that can be helpful in determining whether a work meets the threshold of originality. The most prominent case with respect to 'originality' under the Indian Copyright Law is the "Eastern Book Company v DCB Modak". This judgment gave rise to two doctrines i.e. "modicum of creativity" and the "skill and judgment test". This remains the accepted and current position of law in India as of now. However, prior to this, the Indian Courts used to follow the Sweat of the Brow approach.