Droit moral in selected legal systems of Asia, by example of the right to authorship of a work : where are we coming from, and where are we going

Abstract

The specification of droit moral in Asian countries cannot be encapsulated uniformly in a clear-cut way, as the individual countries present certain dissimilarities in this respect. It is, however, possible to attempt to establish groups showing the general mechanisms governing the development of moral rights in this part of the world. A presentation of the copyright regulations of Asia gains importance if we concentrate on the currently progressing globalisation of intellectual property rights (Jena, 2005: p. 7; Swadźba, 2006: p. 33–39) and the convergence of the Asian countries’ economies (Freeman, 2003: p. 158–159). This analysis will be carried out based on the laws of countries such as: Thailand, Malaysia, Indonesia, Singapore, the Philippines, Vietnam, India, Taiwan, Hong Kong and Japan.