Aquestia Limited filed a patent infringement suit CS (Comm) 860/2024 against Automat Irrigation Pvt. Ltd. alleging that the latter's Hydromat Valve infringed its Indian Patent IN 427050 for a fluid control valve featuring an asymmetric diaphragm and longer inlet path, and obtained an ex parte interim injunction from the Single Judge on 1 August 2025 who limited analysis to the "characterized in that" portion of Claim 1 and found infringement based on asymmetric diaphragm and differential surface areas while ignoring differences in sealing bridge curvature and inlet/outlet path lengths.
Automat appealed, arguing fundamental differences in technology with its curved sealing bridge along the flow axis and symmetric diaphragm with equal path lengths.
The Division Bench reasoned that the Single Judge erred in principle by not construing the claim holistically as required under Indian patent law without special weight to "characterized" portion unlike UK regulations, failing to address equal inlet/outlet paths in appellant's product contrary to suit patent's core feature of longer inlet path, and conflating diaphragm asymmetry with sealing bridge curvature on perpendicular axes.
The court stayed the impugned judgment ad interim pending appeal, finding prima facie errors justifying interference under Wander principles, issued notice returnable on 9 February 2026, and directed filings for potential final disposal.
Law Point:
Patent claims must be construed in their entirety without restricting analysis to the portion following "characterized in that", as Indian Patents Act and Rules lack any such provision unlike UK Implementing Regulation 29(1): Biswanath Prasad Radhey Shyam v. Hindustan Metal Industries, (1979) 2 SCC 511, Para 13; distinguished Guala Closures SPA v. AGI Greenpac Ltd, 2024 SCC OnLine Del 3510, Para 10; Virgin Atlantic Airways Ltd v. Premium Aircraft Interiors UK Ltd, [2009] EWCA Civ 1062, Para 9.
Infringement requires comparing the accused product with the entire claim, including essential features like differing lengths of inlet and outlet flow paths which form the basis of the patented technology: Para 7, Para 10.
Distinction must be maintained between asymmetry of the diaphragm (along flow axis) and curvature of the sealing bridge (perpendicular vs. along flow direction), as conflation ignores fundamental technological differences: Para 11, Para 13.
Appellate courts should not interfere with discretionary interim injunctions in IP matters unless exercised arbitrarily, capriciously, or ignoring settled principles: Wander Ltd v. Antox India P. Ltd, 1990 Supp SCC 727, Para 5; Pernod Ricard India Pvt Ltd v. Karanveer Singh Chhabra, 2025 SCC OnLine SC 1701, Para 6.
Case Title:Automat Irrigation Pvt. Ltd. Vs Aquestia Limited: 05.01.2026: FAO(OS) (COMM) 123/2025 :2026:DHC:3-DB: Mr. Justice C. Hari Shankar and Hon'ble Mr. Justice Om Prakash Shukla.
[Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]
[Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi]
