Court Protects Inox India’s Intellectual Property, Grants Interim Injunction Against Cryogas

Court Protects Inox India’s Intellectual Property, Grants Interim Injunction Against Cryogas

Introduction

The District Commercial Court, Vadodara, has granted an interim injunction in favour of Inox India Private Limited, restraining Cryogas Equipment Private Limited from infringing its copyright in proprietary engineering drawings and confidential technical know-how related to cryogenic and LNG semi-trailers.

Factual Background

Inox India claimed to have been engaged in manufacturing cryogenic storage and transport tanks for over 25 years and had acquired proprietary IP, know-how, and engineering drawings through extensive research and a 2009 acquisition from CVA. Inox alleged that Cryogas, with the help of former Inox employees, copied its proprietary engineering drawings — even replicating spelling errors — and used them to secure PESO approvals for manufacturing similar LNG trailers.

Procedural History

Earlier, the Supreme Court upheld the Gujarat High Court’s dismissal of Cryogas’s plea to reject Inox’s plaint under Order VII Rule 11 CPC and directed the Trial Court to decide the injunction within two months.

Reasoning & Analysis

Justice Priyanka Agarwal held that Inox’s proprietary engineering drawings were prima facie “artistic works” under Section 2(c) and also contained “literary work” elements under Section 2(o) of the Copyright Act. The Court found that the drawings involved artistic expression while also conveying technical information in a structured form. Cryogas’s argument relying on Section 15(2) of the Copyright Act was found unsustainable at this stage. The Court applied the “trinity test” for temporary injunctions, holding that Inox had established (1) a prima facie case, (2) balance of convenience, and (3) irreparable harm.

Findings

The Court found that Inox had established a strong prima facie case, and the balance of convenience lay in its favour. The Court noted that refusal to grant interim protection would result in irreparable loss to Inox and enable Cryogas to unlawfully benefit from Inox’s goodwill without any legal deterrence.

Implications

The decision highlights the importance of protecting intellectual property rights, including proprietary engineering drawings that qualify as both artistic and literary works. The ruling also underscores the need for courts to carefully consider the balance of convenience and potential harm in copyright infringement cases.

Final Outcome

The Court granted an interim injunction restraining Cryogas from infringing Inox’s intellectual property rights and misusing its confidential information until the final disposal of the copyright suit.

In this case the plaintiff was represented by Mr. Rashmin Khandekar along with Mr. J.B. Verma, Advocate. Meanwhile the defendant was represented by Mr. A.V. Sumant, Mr. S.N. Mehta and Mr. P.J. Shah, Advocates.