In a crucial ruling concerning intellectual property law and the enforcement of expired patents, the Delhi High Court has refused to grant interim relief to Toyota Motor Corporation in its ongoing legal battle against Indian firm Lakshmi Machine Works Limited (LMW). The Japanese automobile giant had filed a patent infringement lawsuit alleging that LMW unlawfully used technology related to its proprietary "Spinpact" system—a fibre bundle concentrating apparatus used in textile machinery. Toyota claimed that the Indian firm’s machines incorporated components that were strikingly similar to those protected under its now-expired Indian Patent No. 194088 (IN ‘088). The plaintiff sought a temporary injunction to restrain the defendant from continuing use or sale of machines allegedly infringing upon their patented technology until final adjudication of the suit.
Toyota's claim revolved around a sophisticated component placed downstream of the drafting section in a spinning frame. This fibre bundle concentrating apparatus was developed to enhance the alignment and control of fibres during the spinning process, thereby improving the overall quality and uniformity of the yarn produced. According to Toyota, this mechanism was a part of its unique and innovative technology, and the same was being unlawfully used by LMW without any authorization, thereby constituting willful infringement. The plaintiff argued that the unauthorized use of this apparatus not only violated its patent rights but also resulted in a significant commercial loss and dilution of the value of its innovation. It insisted that the balance of convenience was in its favour, that it had a strong prima facie case, and that irreparable harm would be caused if interim relief was not granted.
The court, however, dismissed Toyota’s plea for temporary relief, primarily on the ground that the patent in question had already expired during the pendency of the litigation. The judgment, delivered by Justice Saurabh Banerjee, firmly reiterated that patents are time-bound statutory rights and once the term of a patent expires, its subject matter falls into the public domain. In the case of Indian patents, the statutory duration of protection is twenty years from the date of filing, and after this period, no legal remedy can be sought to prevent others from using the invention. The judge emphasized that post-expiration, any request to enforce patent rights becomes untenable in law, regardless of whether infringement occurred during the period of validity.
Justice Banerjee acknowledged that Toyota might have a genuine concern about the use of its innovation by a competitor, but he underlined the principle that the court could not step in to protect a right that had already lapsed by operation of law. In this context, it was held that issuing an injunction in respect of a non-existent or expired right would set a dangerous precedent. The court also underscored that injunctive relief is discretionary and equitable in nature and cannot be granted if the legal basis for such protection has ceased to exist. Since the patent had expired on May 24, 2024, there was no enforceable right remaining which could warrant judicial protection under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure.
Interestingly, the court did not disregard the fact that LMW might have commercially benefited from the use of the contested technology during the period when the patent was still valid. To address this aspect, the court directed LMW to furnish an affidavit detailing the financial revenues or gains derived from the sale of machinery that contained the allegedly infringing apparatus between the commencement of use and the date of patent expiry. This affidavit, to be submitted in a sealed cover, will enable Toyota to seek damages, if entitled, at a later stage of the litigation, based on actual commercial exploitation that took place while the patent was still alive. This nuanced direction reflects the court’s attempt to strike a balance between denying enforceability post-expiration while still preserving the plaintiff’s rights to monetary compensation for the past period.
On the other hand, LMW contended that its use of the impugned apparatus was not based on Toyota’s technology but rather developed independently with the assistance of foreign technical partners. The defendant argued that its machines were based on knowledge lawfully acquired through its own research or collaboration with a German company. It further submitted that Toyota’s patent lacked inventive step and was not novel, thus challenging its validity altogether. Although these arguments were not substantively dealt with at this interim stage, they played a background role in reinforcing the court’s decision not to interfere by way of injunctive relief.
The judgment serves as a critical reminder of the temporal limitations imposed by the patent regime. Patent protection is inherently limited by time, and once the designated term expires, the patented subject matter becomes free for use by the public, including commercial exploitation by competitors. The court’s ruling reinforces the doctrine that there is no legal monopoly over a patented product or process beyond its statutory term, even if an infringement suit is pending. This has far-reaching implications, particularly for multinational corporations that file infringement suits late in the life cycle of their patents and expect interim protection to extend beyond expiry.
Furthermore, the judgment subtly cautions litigants against relying heavily on equitable pleas when the statutory framework no longer supports their claims. While equity may supplement legal remedies, it cannot override the express provisions of the patent law. A litigant seeking interim relief must demonstrate not just a prima facie case and potential injury, but also an existing enforceable legal right, which Toyota failed to establish in this case due to the expiry of its patent. The court, therefore, rightly declined to exercise its equitable powers in favour of the plaintiff.
The decision also illustrates how courts may still entertain claims for past damages even after the expiry of the patent, provided the plaintiff can establish commercial harm during the period of validity. By directing LMW to disclose its financial benefits from the use of the apparatus, the court left the door open for compensation, thereby ensuring that Toyota’s substantive rights are not extinguished entirely. However, the possibility of securing an injunction to block further use of the technology was categorically ruled out.
In conclusion, the Delhi High Court's rejection of Toyota’s request for interim injunction underscores the importance of timely enforcement of patent rights and the legal consequences of expiration. While Toyota may still pursue damages for past use, the case affirms that judicial relief cannot extend beyond the life of a patent. The ruling reaffirms a foundational principle of intellectual property law: once a patent expires, it belongs to the public, and courts will not uphold any private monopoly over it thereafter. This judgment will likely serve as a precedent in future cases where plaintiffs seek to restrain post-expiry use of once-patented technology and will remind all stakeholders of the clear boundaries that define the lifecycle of patent protection in India.
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