Case Title: SML Limited Vs. Mohan & Company & Anr.:Date of Order: 6 June 2025:Case Number: OMP No. 320 of 2023 in COMS No. 6 of 2023:Neutral Citation: 2025:HHC:18160:Name of Court: High Court of Himachal Pradesh, Shimla:Name of Judge: Hon’ble Mr. Justice Sandeep Sharma
Very Brief Facts:SML Limited, the plaintiff, is the assignee and holder of Indian Patent No. 282092 titled “Agricultural Composition.” It launched a patented fertilizer product under the brand name “Techno Z.” The defendants allegedly infringed this patent by manufacturing and marketing a similar product under the brand name “Aladdin,” which SML claimed fell within the scope of its patent claims, particularly Claims 11 and 12.
Dispute:The primary dispute was whether the defendants’ product “Aladdin” infringed the plaintiff’s patent and whether the plaintiff was entitled to interim relief by way of injunction under Order XXXIX Rules 1 and 2 of CPC. The defendants challenged the validity of the patent, raised jurisdictional objections, and argued that their product complied with government-mandated fertilizer standards under the Fertilizer Control Order (FCO), not covered by the patent.
Discussion by Judge:The Court carefully examined whether the defendants’ product prima facie fell within the patented claims, relying on expert analysis, claim construction, and comparisons of composition and particle sizes. The judge considered the presumption of patent validity for long-standing patents, the credibility of the defendant’s challenge under Sections 3(d), 2(1)(ja), and 64 of the Patents Act, and public interest arguments under the Essential Commodities Act.
The Court found that the plaintiff demonstrated a prima facie case of infringement and that the defendants failed to raise a sufficiently credible challenge to the patent’s validity at the interim stage. It held that regulatory compliance under FCO could not override proprietary rights under the Patents Act and that balance of convenience favored the patentee.
Decision:The Court granted an interim injunction restraining the defendants from manufacturing, selling, offering for sale, importing, or exporting the allegedly infringing product “Aladdin” or any other product covered under Patent No. 282092. The injunction was to continue until further orders.
