Introduction
This appeal concerns the revocation of Patent No. 452008 titled “An Intelligent Cooking Stove System,” originally granted to Mr. Vijay Srinivasan and later assigned to Maya Appliances Pvt. Ltd. The revocation was made by the Deputy Controller of Patents and Designs following a post-grant opposition filed by Versuni India Home Solutions Ltd. The High Court was called upon to review the validity of this revocation order.
Background and Grounds of Revocation
The patent in question was challenged on four grounds under Section 25(2) of the Patents Act, 1970. The Deputy Controller rejected three objections, including those based on insufficiency of disclosure, lack of novelty, and patent ineligibility under Section 3(f). However, the patent was ultimately revoked solely on the ground of lack of inventive step, particularly with reference to prior art documents D1, D2, and D5.
Appellant’s Contentions
Maya Appliances argued that reliance on prior art documents D2 and D3—originally in Chinese and not taken on record under Rule 61(2) of the Patent Rules, 2003—was improper. The Deputy Controller had explicitly stated that these documents were excluded, yet still relied on their drawings to support the conclusion of lack of inventive step. This inconsistency was challenged as being legally untenable.
It was also pointed out that the Controller did not identify any specific teachings or motivation in the cited prior art that would lead a skilled person to combine their features in a manner leading to the claimed invention. Furthermore, the appellant emphasized that it had enforced the patent in several infringement suits, which were settled in its favor, and that the revocation would enable widespread infringement.
Respondents’ Submissions
The second respondent defended the revocation order by asserting that the decision did not rest solely on D2 and that even the combination of D1 and D5 was sufficient to establish lack of inventive step. It was also argued that the claims were overly broad and resulted in unjust monopoly. The respondent, without prejudice, requested that if the order was to be set aside, then the matter be remanded for fresh consideration of all objections, including those earlier rejected.
Court’s Analysis
The High Court found that the Deputy Controller’s approach was flawed. Although the Controller stated that D2 and D3 were inadmissible due to lack of proper translation, he nonetheless relied on the drawings from D2 to support his conclusion. The Court held that such partial reliance was impermissible under Rule 61(2) and undermined the integrity of the decision-making process.
Further, the Court observed that while the Controller summarized individual features of prior art documents, he failed to explain how a skilled person would be led to combine those features. The absence of any “teaching, suggestion or motivation” to combine references was a significant lapse. The Controller also did not adequately address the rejection of other objections raised in the opposition.
Final Decision
The High Court set aside the impugned order dated 04.04.2025 and remanded the matter for fresh consideration. It directed that the reconsideration be done by an officer other than the one who passed the original order to avoid pre-determination. The Court permitted the filing of translated versions of D2 and D3 and ordered that all parties be given a fair opportunity to present their case, with a reasoned decision to be issued within two months.
Case Details
Case Title: Maya Appliances Pvt. Ltd. Vs Deputy Controller of Patents and Designs
Date of Order: 29 April 2025
Case No.: CMA(PT) No. 5 of 2025
Name of Court: Madras High Court
Name of Judge: Justice Senthilkumar Ramamoorthy
