Delhi High Court Upholds Philips’ Monetary Award Despite Patent Expiry, Denies Stay on Damages Execution

In a significant ruling dated 5 January 2026, the Delhi High Court addressed applications seeking a stay on the execution of monetary decrees awarded in patent infringement suits initiated by Koninklijke Philips N.V. The suits concerned Indian Patent No. 218255, titled “Method of Converting Information Words to a Modulated Signal,” which Philips owned. The defendants in the original suits, including Maj. (Retd.) Sukesh Behl and others, filed Regular First Appeals (RFAs) against the judgment dated 20 February 2025 that had ruled in Philips’ favor.

The patent infringement suits originally sought permanent injunctions to restrain unauthorized use of the patented technology, along with claims for damages and costs. However, during the pendency of the litigation, the patent expired by efflux of time, rendering the injunction reliefs moot. Consequently, the Single Judge’s adjudication focused solely on the claims for damages and costs.

The Single Judge’s judgment found infringement primarily based on Claim 12 of the patent, which pertains to a record carrier containing the modulated signal generated by the patented method. The Court awarded Philips substantial damages, including interest at 12% per annum and additional damages, against the defendants.

Following the judgment, the defendants appealed before the Division Bench of the Delhi High Court and simultaneously filed applications under Order XLI Rule 5 of the Code of Civil Procedure, 1908, seeking a stay on the execution of the monetary decrees pending appeal.

In its order, the Division Bench clarified that issues relating to patent infringement and validity would be addressed at the final hearing stage of the appeals and were not subject to consideration in the stay applications. The Court relied heavily on the Supreme Court’s ruling in Lifestyle Equities C.V. v. Amazon Technologies Inc., 2025 SCC OnLine SC 2153, which emphasized that execution of money decrees is ordinarily not stayed during appeals except in exceptional circumstances.

The Court also referenced precedent from Sihor Nagar Palika Bureau v. Bhabhlubhai Virabhai & Co., Atma Ram Properties (P) Ltd. v. Federal Motors (P) Ltd., and Malwa Strips Pvt. Ltd. v. Jyoti Ltd. to reinforce the principle that monetary decrees should proceed unless compelling reasons exist to halt execution.

Applying these legal standards to the facts, the Court found no exceptional circumstances warranting a stay of execution. It noted that the appellants’ challenges to the judgment remained open for full consideration during the appeals process, but this did not justify delaying enforcement of the damages award.

Accordingly, the Court rejected the stay applications, allowing Philips to proceed with executing the monetary decrees despite the patent’s expiry. This ruling affirms that patent holders may enforce damages awards post-expiry, preserving the legal consequences of infringement findings beyond the patent term.

The case highlights the Delhi High Court’s approach to balancing the rights of patent proprietors to recover damages with procedural safeguards during appellate review. It also underscores the importance for defendants to meet the high threshold required to obtain stays of monetary decrees in patent litigation.