From Holden Caulfield to Chulbul Pandey: A Comparative Analysis of Character Copyright and Fan Fiction under US Fair Use and Indian Fair Dealing

Introduction : On AO3 right now, there are thousands of stories being built around Sherlock Holmes, Jane Austen's Elizabeth Bennet, and half the Marvel roster, written by fans who own none of the source material. On Wattpad, Indian readers do the same thing with Chulbul Pandey from Dabangg, Bajirao from Bajirao Mastani, and the extended universe of Yash Raj Films. Both sets of writers are doing something identical: borrowing a character someone else invented and taking it somewhere new. If a...