This theory bases the grant of copyright protection on the effort and labour that an author puts into his or her work as opposed to the creativity involved. Locke's theory of labour as property has often been extended to give jurisprudential basis to this theory of copyright law. In the case of "V. Govindan v E.M. Gopalakrishna Kone," it was held that compilations of information would meet the threshold of 'originality' under the Indian Copyright Act since it involves some level of 'skill, labour and brain'. A similar line of reasoning was adopted in the case of "Burlington Home Shipping Pvt Ltd v Rajnish Chibber" where a database was held to be original enough to be protected by copyright under Indian law. Like in other jurisdictions, however, this theory was discarded by the Indian Courts also and the focus was shifted to the creativity involved in any work.