Factual Matrix 

In the instant case of TTK Prestige Ltd. v. Gupta Light House The defendant, Gupta Light House, was accused of violating the design of a cooker that the plaintiff, TTK Prestige Ltd., had registered in its favour. The design of a cooker that had been registered in the plaintiff’s favour by the Design Office in the Patent Office was allegedly violated by the defendant, according to the plaintiff. The registration certificate attested to the cooker’s uniqueness in terms of its design and setup. According to the plaintiff’s claims, the defendant engaged in design piracy when it manufactured and marketed pressure cookers that were plainly or dishonestly similar to registered suit designs, as defined by Section 22(1) of the Act.

Analysis of Court Order 

A clear instance of piracy within the meaning of Section 22(1) of the Patterns Act, 2000 exists, according to the single judge bench of the Delhi High Court led by Justice C. Hari Shankar, who found that the defendant’s pressure cookers copied the patterns at issue. However, the Court further ruled that because the suit design had expired in 2019 and was therefore no longer in use, there could be no judgement or decree prohibiting anybody from using the suit design. An order of rendition of accounts against the defendant was also granted to the plaintiff, according to the court’s ruling.

The court determined that the plaintiff’s cooker was registered legally as of December 13, 2004. According to the cooker’s registration certificate, it was unique in both design and configuration, with a protruding middle. This design met the requirement for registration as a design in that it had a distinctive visual appeal. The court argued that it was obvious that the defendant’s product was an imitation of the suit design when the defendant’s product was compared to both the plaintiff’s product and the suit design. The fact that there were no images or depictions of a pressure cooker with a design resembling that of the garment before December 13, 2004, does not imply that the suit design was unsuitable for previous publishing. Due to the uniqueness of the outfit, it was plausible that other manufacturers had duplicated it.

The court determined that the defendant’s pressure cookers violated Section 22(1) of the Act because they were direct imitations of the designs at issue in the lawsuit. The court determined that the defendant had expired in 2019 and declared the design to be in the public domain. The plaintiff was given the option of suing the defendant for real court expenses and damages. On August 29, 2023, the issue would be scheduled before the tax officer to determine expenses.

CASE NAME – TTK Prestige Ltd. v. Gupta Light House, CS (COMM) 865 of 2022