Cannot Claim Lifetime Monopoly: Delhi High Court Refuses Interim Injunction to Toyota in Patent Infringement Case

The Delhi High Court dismissed an application seeking interim injunction filed by Toyota to restrain LMW Limited from using its patented products.

The Court observed that since the patent in question has already expired on May 24, 2025, the Court is precluded from passing any effective order restraining infringement of the said patent as any finding on the merits by the Court would be a nullity and are likely to prejudice the fate of the present proceedings.

The Bench of Justice Saurabh Banerjee observed, “The period prescribed therein for a maximum period of twenty years in the Act is with a specific purpose. The Legislature, in its wisdom, has prescribed the said period of twenty years keeping in mind the overall social and economic benefit of humanity at large, and especially that no patent holder like the plaintiff, can be allowed to claim a lifetime monopoly over a patent after its term, once it has expired. Thus, this Court being bound by the stipulations of the Statute/ Act, granting an injunction of the nature sought by the plaintiff herein, and that too at this stage, when the life/ term/ period of the patent IN759 has already expired, would lead to anomalies and in fact, be futile. This Court cannot grant anything by way of the reliefs sought for in the present proceedings, particularly, since it would be beyond the scope thereof and/ or will be what is neither statutorily available nor permissible.”

Case Brief

Toyota contended that the defendant is using/ intending to use and supply its patented technology claimed and granted in IN759 and IN883 without authorization from the plaintiff in its spinning machine known as Spinpact.

However, the Defendant filed a Counter Claim praying for declaration of both IN883 and IN759 as invalid and revocation of the same under Section(s) 64 and 107 of the Act, on the ground of lack of novelty and inventive step, for the technology therein being used prior to the priority date claimed in the patent, as also for the same being obvious in light of the prior art(s).

Court’s Analysis

The Delhi High Court opined that the patent, as claimed by Toyota, has already expired on May 24 2025, thus it would be imperative for the Court to dwell into the viability of the present application under Order 39, Rules 1 and 2 of the CPC.

The Court referred to Section 53 of the Patents Act and emphasised that after expiration of the term of twenty years, the patent shall cease to have effect. Thus, the life of the ‘expired’ patent cannot be renewed by a patent holder since it lapses once the said mandatory period of twenty years is over. Resultantly, upon expiry of the said mandatory period of the term of twenty years of the patent, the patent holder cannot seek to claim any kind of protection.

“Applying the aforesaid provisions to the factual matrix involved herein, it entails that the said patent, IN759, upon expiry of the limited/ mandatory period of twenty years on 24.05.2025, is freely available in public domain now, more so, since there is interestingly no provision for renewal thereof in the Act. Therefore, once in public domain, everyone including the defendant herein, is/ will be free to use, manufacture, offer, sell, or like, IN759 in any form whatsoever. This is since the plaintiff has lost its right to enforce the said IN759 after the expiry of the limited/ mandatory period of twenty years”, the Court observed.

The Court also opined that as far as the apprehensions of Toyota in relation to Spinpact products manufactured during the existence of IN759 are concerned, the same can be compensated through costs at the final determination of the pending litigation.

“Thus, even though the plaintiff may have a prima facie case with the balance of convenience in its favour and a likelihood of irreparable harm, loss and injury to it, the fact of expiry of the patent of the plaintiff is a crucial factor which would decide the fate of the present application”, the Court added.

Resultantly, the Court observed that since IN759 has already expired on May 24, 2025 no effective order restraining infringement of the said patent can be passed as any finding on the merits by the Court would be a nullity and are likely to prejudice the fate of the present proceedings.

Accordingly, the Application was disposed off.

Cause Title: Kabushiki Kaisha Toyota Jidoshokki V. Lmw Limited (Neutral Citation: 2025:DHC:5122)

Appearance:

Plaintiff: Senior Advocate C.M. Lall, Advocates Pravin Anand, Archana Shanker, Sagar Arora, Annanya Mehan and Ashutosh Upadhyaya

Defendant: Senior Advocate Gaurav Pachnanda, Advocates Vineet Rohilla, Pankaj Soni, Debashish Banerjee, Ankush Verma,Rohit Rangi and Namrata Sinha

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