The Delhi High Court has stayed the operation of an interim injunction granted by a Single Judge in a patent infringement suit involving fluid control valves used in irrigation systems, observing that the impugned order suffered from errors of principle in patent claim construction.
A Division Bench comprising Justice C. Hari Shankar and Justice Om Prakash Shukla was hearing an appeal filed by Automat Irrigation Pvt. Ltd. and others, challenging a Single Judge order dated August 1, 2025, which had restrained them from manufacturing and selling their “Hydromat Valve” on the ground that it infringed a patent held by Aquestia Limited.
The Single Judge had held that Automat’s product infringed Claim 1 of Aquestia’s Indian Patent, primarily by focusing on the portion of the claim following the words “characterized in that”. However, the Division Bench found this approach to be prima facie flawed, noting that Indian patent law does not accord special or exclusive significance to the “characterized” portion of a claim, unlike certain European or UK patent regimes.
The Court observed that claims under the Patents Act, 1970 must be construed holistically, and infringement must be assessed by comparing the entire claim with the allegedly infringing product. Restricting analysis only to the “characterized” portion, the Bench held, was contrary to settled Indian law and Supreme Court precedent.
On facts, the Bench noted significant prima facie differences between the patented invention and Automat’s product, including the nature and axis of curvature of the sealing bridge, the symmetry of the diaphragm, and the length of inlet and outlet flow paths. It observed that the Single Judge appeared to have conflated distinct technical features and failed to examine whether several essential elements of the patented claim were actually present in the appellants’ valve.
While acknowledging the settled principle that appellate courts should ordinarily refrain from interfering with discretionary interim orders in intellectual property matters, the Bench held that interference was warranted in the present case due to fundamental errors in understanding the invention and applying patent law principles.
Accordingly, the Division Bench stayed the operation of the interim injunction at the ad-interim stage, making it clear that its observations were prima facie in nature and that the matter would be examined in greater detail at the final hearing of the appeal. The Matter is now listed for February 9, 2025.
Appearances
Appellants- Mr. J. Sai Deepak, Sr. Adv. with Mr. Avinash Sharma, Ms. Somya Chaturvedi, Mr. Shrey Sharma, Mr. Shreesh Chadha, Advs.
Respondents- Mr. Pravin Anand, Ms. Vaishali Mittal, Mr. Siddhant Chamola and Mr. Gursimran Singh Narula, Advs.
