Delhi High Court Faults Claim Construction, Stays Interim Patent Injunction

Delhi High Court Faults Claim Construction, Stays Interim Patent Injunction

Introduction

The Delhi High Court has stayed an order restraining an Indian irrigation equipment manufacturer from selling its product. The Court held that the earlier injunction suffered from serious errors in patent claim interpretation and infringement analysis, warranting appellate intervention despite the general restraint exercised in such matters.

Factual Background

The dispute arises from a patent infringement suit filed by Aquestia Limited, which owns a patent relating to FCV (Flow Control Valve) technology. The suit alleged that the “Hydromat Valve”, manufactured by Automat Irrigation Pvt. Ltd., infringed Claim 1 of Aquestia’s patent.

The Single Judge, at the interim stage, accepted the infringement allegation and restrained Automat Irrigation from manufacturing and selling the Hydromat Valve.

Procedural Background

Aggrieved by the interim injunction dated August 1, 2025, Automat Irrigation preferred an appeal before a Division Bench of the Delhi High Court. The appeal was heard by Justices C. Hari Shankar and Om Prakash Shukla, who pronounced their decision on January 5, 2026.

Issues

1. Whether the Single Judge had correctly construed the patent claims while granting interim relief.

2. Whether the finding of prima facie infringement was legally sustainable.

3. Whether the appellate court could interfere with a discretionary interim order in a patent dispute.

Contentions of the Parties

Appellants: Automat argued that the Single Judge had committed a fundamental error by examining only a limited portion of Claim 1, rather than construing the claim as a whole. It was contended that Indian patent law does not recognise any special status for the portion of a claim following the words “characterized in that”, and that crucial technical distinctions between the Hydromat Valve and the patented technology were overlooked.

Respondents: Aquestia defended the interim order, relying on the settled principle that appellate courts ordinarily refrain from interfering with discretionary interim orders, particularly in intellectual property matters, unless manifest illegality is shown.

Reasoning and Analysis

The Division Bench reiterated the principle laid down by the Supreme Court in Wander Ltd. v. Antox India Pvt. Ltd., that appellate courts should ordinarily not interfere with discretionary interim orders. However, it clarified that this restraint does not apply where discretion is exercised on an incorrect understanding of law.

Moreover, the Court found that the impugned order suffered from a basic misunderstanding of the invention forming the subject matter of the suit patent and of the manner in which Automat’s product was fundamentally different. The Bench held that Indian patent law requires claims to be construed holistically, in light of the complete specification. It categorically rejected the approach of confining infringement analysis to the portion of the claim following the words “characterized in that”, observing that Indian law does not accord any elevated or special status to that part of a claim.

The Court further noted that reliance on foreign jurisprudence particularly UK regulations that have no statutory parallel in India was misplaced. It also found that the Single Judge failed to consider crucial distinguishing technical features, especially in the manner in which fluid flow is regulated in the competing technologies. In view of these prima facie legal and factual errors, the Court concluded that the interim injunction could not be allowed to operate.

Decision

The Delhi High Court stayed the operation of the Single Judge’s order restraining Automat Irrigation from selling the Hydromat Valve. Holding that the impugned order suffered from serious infirmities in claim construction and infringement analysis, the Court issued notice in the appeal and directed that the stay shall continue until further orders. The matter has been listed for further hearing on February 9, 2026.

In this case the appellant was represented by Mr. J. Sai Deepak, Sr. Adv. with Mr. Avinash Sharma, Ms. Somya Chaturvedi, Mr. Shrey Sharma and Mr. Shreesh Chadha, Advocates. Meanwhile the respondent was represented by Mr. Pravin Anand, Ms. Vaishali Mittal, Mr. Siddhant Chamola and Mr. Gursimran Singh Narula, Advocates.