Delhi High Court’s Decision on Design Infringement: Philips vs. Jaiprakash Agarwal

In a recent landmark ruling, the Delhi High Court has shed light on the intricate world of design infringement and passing off suits, with its decision in the case of Philips Holding B.V. v. Jaiprakash Agarwal & Anr. The court’s judgment, issued on July 5, 2022, carries significant implications for the protection of innovative designs in India.

Design Novelty Dispute: T-Shape and Plug and Play

The plaintiffs, Philips Holding B.V., contended that the uniqueness of their electric bulbs lay in their distinctive T-Shape and Plug and Play format. They argued that the designs used by the defendants bore a striking resemblance to their own. To bolster their case, the plaintiffs presented a comparative report highlighting the undeniable similarities between the two sets of designs.

The Defendants’ Defense

In response, the defendants maintained that their designs were distinct and separate from those of the plaintiffs. They also asserted that the plaintiffs’ designs could potentially be invalidated due to the existence of prior, similar design registrations in India. The defendants further supported their case by presenting multiple design registrations for the same products.

Court’s Verdict: A Delicate Balancing Act

Upon careful examination of the arguments put forth by both parties, the court acknowledged the visual similarities between the designs. However, it ultimately concluded that the plaintiffs’ bulb designs were, in essence, trade-variants of pre-existing registered designs and, thus, ineligible for further registration.

Furthermore, the court rejected the plaintiffs’ plea of passing off, highlighting that the plaintiffs were not only the originators of these designs but also acted as the original equipment manufacturers for various lighting products for multiple companies. This association made it challenging to attribute the product exclusively to the plaintiffs.

This ruling in Philips Holding B.V. v. Jaiprakash Agarwal & Anr. sets a noteworthy precedent in design infringement cases, emphasizing the need for a delicate balance between protecting innovation and recognizing the limitations of design registration. As the legal landscape evolves, it is imperative for designers and manufacturers to navigate these complexities with care to safeguard their creative endeavours.