Case Name: Jay Switches India Pvt Ltd. Vs Sandhar Technologies Ltd. & Ors.
Case Number: Civil Suit (Commercial) 301 of 2023
Date: 02nd December 2024
Quorum: Hon’ble Mr. Justice Amit Bansal
FACTS OF THE CASE
The plaintiff, Jay Switches India Pvt Ltd, alleged infringing of patent against Sandhar Technologies Ltd. and others, with the plaintiff claiming that the design of the fuel cap by the defendants was an infringement of a patent registered under the said title of “Air Tight Fuel Cap”. The fuel cap was patented on March 27, 2023, to preserve air pressure in the fuel tank of a vehicle against leaks and spills during service. The interim injunction sought by the plaintiff restrained the defendants from manufacturing and marketing the product alleged to be infringing.
The defendants pleaded against the infringement plead-for, stating that their product was of distinctive structural, functional difference from the patent of the plaintiffs; hence, it does not infringe on it. The dispute involved the construct of some claims under the patent the “main circular plate” and the “engagement projections,” besides whether the defendants’ product fell in those claims. The plaintiff contended that the fuel cap manufactured by the defendants was a copy of one of an important aspect of its original design as to the arrangement and working of the lock and the main circular plate. The defense came back with an emphasis on structural and functional uniqueness of its design associated with the patent’s “spacing features” and the interplay of the main circular plate. It had significant implications for the construction of claims and history associated with the resultant theory of galvanization in constructing enforcement for patenting of obviousness.
ISSUE OF THE CASE
Whether the plaintiff’s patent was violated by the defendants’ product?
LEGAL PROVISIONS
- Order XXXIX, Rule 1, Code of Civil Procedure, 1908 (CPC)
Discuss the provision for the issuance of temporary injunctions to halt rights violations during pending litigation.
- Order XXXI, Rule 1, Code of Civil Procedure, 1908 (CPC)
Describes application for and securing temporary injunctions according to the provisions of the Code of Civil Procedure.
- Section 10(4)(c) of the Patents Act of 1970
Lays down the breadth of a patent through claims which must have enough precision and do not afford ambiguity in claim and be entirely supported by the specifications.
- Section 58 of the Patent Act of 1970
Allows for the amendment of claims provided that such amendment does not amplify the scope of a patent, providing judicial precedents.
ARGUMENTS
Arguments of Plaintiff (Jay Switches India Pvt. Ltd.)
Jay Switches India Pvt Ltd, the plaintiff, claimed that the fuel cap design of the defendants infringed its patent, namely, claims 1 and 2, which mentioned certain structural and functional elements. Projections for engagement should fall within the “predetermined distance” mentioned in Claim 1, ranging from 10% to 100% of the “length of the main circular plate,” they asserted, since they are a crucial element of the main circular plate. To their credit, the plaintiff quoted Claim 2, which refers to the engagement projections as part of the main circular plate. Despite minimal differences in design, the defendants were knowingly violating the patent by imitating the plaintiff’s patented design, the plaintiff further put forth. To elucidate the allegations, the plaintiff added additional background information, declaring it had bolstered its case and should be accordingly compensated.
Arguments of the Defendant (Sandhar Technologies Ltd. & Ors.)
The defendants, Sandhar Technologies Ltd. and others, contended that their device did not come under the purview of the patent and, hence, cannot violate it. According to them, what the phrase “predetermined distance” implied, in respect of their product, exceeding that 10% to 100% limit of “the length of the main circular plate,” does not, in practice, restrict it to this notion as laid out in Claim 1. According to the defendants, the patent drawings and numeral references indicated that the engagement projections were separate from the main circular plate. They argued that there were ambiguities in the plaintiff’s claims, particularly owing to amendments during the patent prosecution process, raising serious questions on the precision and extent of these claims. They argued that no interim injunction should be granted because these uncertainties should be resolved by full trial evidence, including expert testimony.
ANALYSIS
The court reviewed the scope of Claim 1 and in particular the interpretation of the terms “predetermined distance” and “length of the main circular plate.” The court endeavored to arrive at a conclusion that given the engagement projections clearly mentioned in the patent specifications, they were not included in the definition of “length” and were confined only to the primary circular plate. Even though the engagement projections form part of the main circular plate specifically included in Claim 2, the court took time to point out that this did not enhance the coverage of Claim 1. Although recognizing the bleeding scope the amendments throughout the prosecution must have brought to grievance in the claims themselves, it directed forces against the very citation of such daily visible variations. With these uncertainties and need for expert testimony in full swing, the court ruled against the plaintiff’s request for an injunction against defendants, ruling that the matter could not be settled later on.
JUDGEMENT
Locating the prima facie proof of infringement presented by the plaintiff, the court declined the request for an interim injunction. Importantly, for the allegations of the plaintiff to be properly elaborated, trial evidence needed to be filed, as there was plenty of ambiguity involved, especially with regard to scope relating to the main circular plate and engagement projections.
The case went on to say that the defendants would be put in a more difficult position because an injunction would interfere with their ability to conduct business. The Defendants, however, were ordered to maintain records of their product sales and were to deliver returns regularly to ensure accountability. The Court stated conclusively that its conclusions were to apply only at this stage of the proceedings and would not, in any way, affect the outcome of the case.
CONCLUSION
This ruling underscore the importance of careful drafting of patent claims and the difficulty in enforcing patent rights if expressions used in a patent are vague. It reiterates the importance of having robust evidentiary support and expert testimony in the resolution of complex patent issues. The balance between impairment of intellectual property rights and interruption of commercial operations led the tribunal to deny the temporary injunction. The ruling reminds the courts to indulge in a very cautious application of temporary relief in patent cases, in ensuring the trial embraces meatier issues in detail.
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WRITTEN BY MADHAV SAXENA
