2025 High Court Decisions Highlight Key Developments in Indian Intellectual Property Law

The Indian High Courts delivered several pivotal judgments in 2025 that clarify and reinforce principles governing intellectual property rights across patents, trademarks, copyrights, and trade dress.

In Crystal Crop Protection Ltd. v. Safex Chemicals India Ltd., the Delhi High Court examined patent infringement under the doctrine of equivalents. The suit patent’s independent claims covered a dyeing agent or pigment, whereas the defendants’ products lacked these components. The defendants argued this difference excluded them from infringement. The Court held that where no literal infringement exists, infringement by equivalents must be considered by assessing whether the defendant’s product achieves the same result in substantially the same way as the inventive concept. After reviewing the patent’s specification, claims, and prosecution history, the Court found no prima facie infringement by equivalence. The balance of convenience favored the defendants, and the application for interim injunction was dismissed.

In trademark law, Eureka Forbes Ltd. v. Nandan Sales involved the registered mark “AQUAGUARD” and other formative marks. The Court found the defendants’ unauthorized use of “AQUA” marks was deliberate and unjustified, intended to capitalize on the plaintiff’s goodwill. This unauthorized use was likely to cause consumer confusion, dilute the distinctiveness of the plaintiff’s brand, and erode public trust. The Court recognized this as a clear case of trademark and copyright infringement and disposed of the petition accordingly.

The Delhi High Court also addressed copyright society registration in Azure Hospitality (P) Ltd. v. Phonographic Performance Ltd. The case focused on whether PPL, no longer a registered copyright society, could grant licenses for sound recordings. Under Sections 18 and 33 of the Copyright Act, 1957, and the 2012 Amendment, only registered copyright societies may issue licenses. The Court held that copyright owners must be members of a registered copyright society to grant licenses. The Court modified the order and allowed the appeal, emphasizing the need to balance equities in copyright licensing enforcement.

Trade dress protection featured prominently in two cases involving the Coat-Pocket Edition of the Constitution of India. In EBC Publishing (P) Ltd. v. Rupa Publications India (P) Ltd., the Court found the defendant’s imitation of the plaintiff’s distinctive colour scheme, layout, typography, container shape, and embossed gold detailing constituted prima facie trade dress infringement. The Court noted that consistent use of distinctive colour combinations creates customer recognition and goodwill, and substantial reproduction risks consumer confusion and dilution of distinctiveness.

Similarly, in EBC Publishing (P) Ltd. v. Young Global Publications, the Court granted an interim injunction against the sale of deceptively similar copies. The plaintiffs and defendants operated in the same business line, utilized identical trade channels, and catered to the same customer base, creating a strong likelihood of confusion. The Court found irreparable harm would occur without the injunction and ruled in favor of the plaintiffs.

In Manash Lifestyle (P) Ltd. v. Viraj Harjai, the Delhi High Court dealt with trademark infringement under the Trade Marks Act, 1999. The petitioner alleged that the respondent’s mark “PURPLLE TREE,” which added “TREE” to the established “PURPLLE” mark, was deceptively similar and likely to confuse consumers. Despite the respondent’s argument that the marks were registered in different classes, the Court held that the phonetic and structural similarity amounted to dishonest adoption. The Court cancelled the registration of the impugned marks and allowed the petition.

Finally, in Minda Spectrum Advisory Ltd. v. Jagdish Kumar, the Court addressed infringement of a well-known trademark and contempt of court. The defendants used a deceptively similar mark in violation of an undertaking and court orders. The Court found wilful disobedience amounting to contempt and imposed compensatory and aggravated damages. A permanent injunction was granted to protect the plaintiff’s rights.