Dura-Line India Pvt Ltd Vs Jain Irrigation Systems Ltd.

Case Title: Dura-Line India Pvt Ltd Vs Jain Irrigation Systems Ltd.Court: High Court of DelhiJudgment Date: 19th May 2025Case Number: CS(COMM) 245/2017 Order Date: 19th May 2025Neutral Citation:  2025:DHC:4036 Judge: Hon’ble Mr. Justice Sanjeev Narula

Fact

Dura-Line India Pvt Ltd (Plaintiff) filed a lawsuit against Jain Irrigation Systems Ltd (Defendant) alleging infringement of Indian Patent No. IN 199722 and Design Registration No. 192665. The patent relates to a non-metallic pipe with a co-extruded tracer cable embedded on its outer surface, enabling precise underground detection of leaks. Dura-Line contended that Jain’s products, marketed as “Jain Insta Tracer Pipes,” incorporate the essential features of their patented invention, infringing upon their rights. Jain Irrigation challenged the validity of the patent, claiming it lacked novelty and inventive step.

Procedural Detail

• The suit was initiated in 2013 (originally numbered CS(OS) 796/2013) and later renumbered as CS(COMM) 245/2017 under the Commercial Courts Act.
• Extensive hearings spanned over a decade, including the appointment of a Local Commissioner and allegations regarding the patent’s validity.
• The Court examined technical evidence, patent claims, and prior art references, while also considering the trade and contractual context related to the irrigation project.

Issue

• Whether Jain Irrigation’s products infringe upon Dura-Line’s patent for a tracer-embedded pipe? 
• Whether the patent IN 199722 is valid, considering allegations of lack of novelty, inventive step, and insufficient disclosure? 

Decision

• The Court held that Jain’s products do infringe the patent, as they embody the core features claimed by Dura-Line.
• The patent was found valid; the Court upheld the patent’s validity, including the specific structural and functional features.
• The suit was decreed in favor of Dura-Line, and the Court directed the issuance of a certificate confirming the patent’s validity.
• The Court also ordered Jain Irrigation to render accounts of profits and pay costs, reaffirming principles under the Commercial Courts Act and relevant legal standards.