Safiya Malik

The High Court of Delhi Division Bench of Justice C Hari Shankar and Justice Om Prakash Shukla stayed, until the next hearing, the operation of a single-judge order that had stopped an Indian irrigation equipment maker from selling its fluid control product marketed as the “Hydromat Valve”. The earlier order had granted interim relief to the patent holder, holding that the product prima facie infringed the respondent’s Indian Patent IN 427050. In appeal, the manufacturer challenged the injunction and the finding of prima facie infringement. Pronouncing judgment on January 5, 2026, the Bench kept the impugned restraint in abeyance pending further consideration of the patent infringement dispute. The stay will continue to operate until the matter is heard next.

The appeal arose from an interim order passed by a Single Judge of the High Court of Delhi in a commercial patent infringement suit concerning a fluid control valve. The respondent, as plaintiff, alleged that the appellants’ product infringed its patented invention and sought interim injunctive relief. The Single Judge allowed the application and restrained the appellants from manufacturing and selling the impugned product.

Also Read: Remand Leaves Undecided Issue Open; Adjudicating Authority Applies Binding Law As On Decision Date : Supreme Court

Aggrieved, the appellants preferred an appeal before the Division Bench, contending that the Single Judge had erred in the infringement analysis by confining the comparison to the “characterised” portion of the principal claim and by overlooking material technical distinctions between the patented invention and the appellants’ product. The appellants relied on pleadings, patent specifications, expert material, and their own subsequently granted patent to assert non-infringement.

The respondents opposed the appeal, maintaining that all essential features of the suit patent were present in the appellants’ product and that the Single Judge’s exercise of discretion at the interlocutory stage did not warrant appellate interference.

The appeal was heard at the stage of issuance of notice, limited to consideration of interim relief.

The Division Bench noted that appellate interference with discretionary interim orders is limited, but clarified that such restraint does not apply where the order suffers from errors of principle. The Court observed that “the impugned order of the learned Single Judge suffers from a basic misunderstanding of the nature of the invention forming subject matter of the suit patent and the manner in which the product of the appellants are fundamentally different from the subject matter of the suit patent.”

On claim construction, the Court recorded that “there is nothing, in the Patents Act or the Patents Rules, which justifies restricting the construction of the Claim, in a granted patent, to the part of the Claim which follows after ‘characterized in that’.” It stated that Indian patent law does not accord statutory primacy to any segment of a claim and that claims must be construed holistically.

The Bench further observed that “the claim has to be construed, holistically and in its entirety” and that limiting infringement analysis only to the characterised portion was “contrary to the law as it exists in India.”

On technical comparison, the Court noted that the Single Judge had failed to consider distinctions relating to inlet and outlet path lengths, which were integral to the patented technology. It recorded that “the inlet and outlet chambers in the case of the appellant’s FCVs are of equal length” unlike the patented configuration.

Addressing diaphragm asymmetry, the Court stated that “the finding, in the impugned judgment, that the sealing diaphragm is asymmetrical is, prima facie, contrary to the record.” It observed that the Single Judge had conflated curvature of the sealing bridge with asymmetry of the diaphragm, despite both operating on different axes.

The Bench also observed that “the FCV forming subject matter of the suit patent is different and distinct, not only in its main features, but even in the guiding technology whereby fluid flow is regulated.”

The Court directed that “let notice issue in the appeal, as well as in CM 49211/2025, returnable on 9 February 2026,” and recorded that “notice is accepted by Mr. Pravin Anand. The requirement of exchange of pleadings in the appeal” stands dispensed with. However, the Court granted liberty to the respondents “to file response in CM 49211/2025 within four weeks with advance copy to the appellant,” and further permitted the appellant “to file rejoinder thereto within four weeks thereof.”

Also Read: Delhi High Court Cancels “ACTIVEPUSHPA” Trademark, Finds It Deceptively Similar To “HEMPUSHPA”

The learned counsel appearing for the parties “to file written submissions in the appeal, not exceeding five pages on each side,” and required that such submissions be “accompanied by duly indexed compilations of any judicial authorities” relied upon, “within four weeks, after exchanging copies with each other.”

The matter be “renotified in the Supplementary List on 9 February 2026 tentatively for disposal of the appeal itself. Till the next date of hearing, the operation of the impugned judgment shall remain stayed.”

Advocates Representing the Parties

For the Appellants: Mr. J. Sai Deepak, Senior Advocate, with Mr. Avinash Sharma, Ms. Somya Chaturvedi, Mr. Shrey Sharma, Mr. Shreesh Chadha, Advocates
For the Respondents: Mr. Pravin Anand, with Ms. Vaishali Mittal, Mr. Siddhant Chamola, Mr. Gursimran Singh Narula, Advocates

Case Title: Automat Irrigation Pvt. Ltd. & Ors. v. Aquestia Limited & Anr.
Neutral Citation: 2026: DHC:3-DB
Case Number: FAO(OS) (COMM) 123/2025
Bench: Justice C. Hari Shankar, Justice Om Prakash Shukla