The Delhi High Court, refused to grant an interim injunction sought by Jay Switches India Pvt Ltd (“Jay Switches”) against Sandhar Technologies Ltd. and others (“Sandhar”) in a patent infringement dispute. The case centered on Jay Switches’ registered patent (No. 427110), titled “Air Tight Fuel Cap” (“Suit Patent”), allegedly infringed by Sandhar’s fuel cap (Model No. COML-13), marketed as suitable for Tata Ace vehicles. Jay Switches sought to restrain Sandhar from manufacturing or selling the impugned product, claiming it violated Claim 1 and Claim 2 of the Suit Patent.
Background of the Suit and Plaintiff’s Contentions
Jay Switches, a manufacturer of automotive components, alleged that Sandhar’s fuel cap incorporated the same structural and functional features as its patented design, thus violating the patent. Jay Switches emphasized that Sandhar’s product employed a “predetermined distance” between locking projections and the main circular plate, a critical feature covered under Claim 1 of the Suit Patent. The plaintiff further argued that the main circular plate includes “engagement projections,” contrary to Sandhar’s claim that these were distinct components.
Jay Switches contended that Sandhar had willfully copied its patented design to compete unfairly in the market, particularly by targeting Jay Switches’ key customer, Tata Motors. Evidence of infringement was supported by an affidavit from Jay Switches’ in-house expert, mapping the features of the impugned product against the claims of the Suit Patent.
Defendants’ Contentions
Sandhar denied the allegations, arguing that their product was structurally and functionally different from the Suit Patent. They contended that the “predetermined distance” in their product exceeded the patented range (10-100% of the length of the main circular plate). Furthermore, Sandhar maintained that the main circular plate and engagement projections were separate entities, as evidenced by the patent’s prosecution history and technical drawings. Sandhar also highlighted inconsistencies in Jay Switches’ interpretation of the claims, suggesting ambiguity in the patent’s scope.
Court’s Analysis
The primary issue before the Court was the construction of Claim 1 of the Suit Patent, particularly the interpretation of the “length of the main circular plate” and whether it included the engagement projections. The Court emphasized that patent claims define the invention’s scope and must be read as ordinary sentences without adding or subtracting elements. It referred to relevant case law and guidelines on claim construction, observing that reference signs in the drawings serve as interpretative aids but do not expand the scope of claims.
The court analyzed the prosecution history of the Suit Patent, noting that amendments made during the patent’s examination clarified that the length referred solely to the main circular plate (MCP) without engagement projections (EP). This was corroborated by the plaintiff’s own submissions during pre-grant opposition proceedings. The Court further rejected Jay Switches’ attempt to amend the claims post-grant to alter this interpretation, stating that such changes were belated and intended to overcome the defendants’ non-infringement argument.
The Court also dismissed Jay Switches’ assertion that the engagement projections were integral to the main circular plate. Relying on the complete specification and figures provided in the patent, the Court concluded that the engagement projections were distinct features, separately identified and referenced in Claim 2.
Court’s order
On a prima facie basis, the Court held that Sandhar’s product did not infringe either Claim 1 or Claim 2 of the Suit Patent. The defendants’ interpretation of the claims, particularly the exclusion of engagement projections from the length of the main circular plate, was found consistent with the patent’s language and drawings.
The Court found that granting an injunction would disproportionately harm Sandhar, given its established manufacturing commitments and market presence. Conversely, Jay Switches failed to demonstrate irreparable harm that could not be compensated monetarily. The Court also noted the lack of clarity in the patent claims, making it inappropriate to grant interim relief before trial and expert evidence.
The Court therefore dismissed Jay Switches’ application for an interim injunction and relieved Sandhar from an earlier undertaking to restrict sales. However, the defendants were directed to maintain detailed accounts of the manufacture and sale of the impugned products and file statements of accounts semi-annually.
Conclusion
The decision in this case underscores the importance of precise claim drafting and prosecution history in patent infringement cases. It also highlights the Court’s reluctance to grant interim relief where patent claims are ambiguous and infringement cannot be established without detailed evidence.
Citation: Jay Switches India Pvt Ltd v. Sandhar Technologies Ltd & Ors, CS(COMM) 301/2023 (H.C. Delhi Dec. 2, 2024). Available at: https://indiankanoon.org/doc/117825252/
Authored by Gaurav Mishra, BananaIP Counsels
Disclaimer
The case note/s in this blog post have been written by IP Attorneys at BananaIP Counsels based on their review and understanding of the Judgments. It may be noted that other IP attorneys and experts in the field may have different opinions about the cases or arrive at different conclusions therefrom. It is advisable to read the Judgments before making any decisions based on the case notes.
If you have any questions, or if you wish to speak with an IP expert/attorney, please reach us at: contact@bananaip.com or 91-80-26860414/24/34.
