Court Finds No Prima Facie Case of Novelty or Infringement in Ceiling Fan Design Dispute with Stove Kraft
In a significant ruling, the Bombay High Court, presided over by Justice Gauri Godse, dismissed an interim application filed by Atomberg Technologies Private Limited against Stove Kraft Limited, alleging design infringement and passing off related to ceiling fans. The case, registered as Interim Application No. 88 of 2026 in Commercial (IP) Suit No. 710 of 2025, was decided on April 17, 2026.
Atomberg Technologies had sought interim relief for what it claimed was an infringement of its registered design for a ceiling fan, along with allegations of passing off by Stove Kraft Limited. The plaintiff argued that its fan design was novel and unique, emphasizing features such as blade shape and configuration, which they asserted had been imitated by the defendant's product.
However, after thorough examination, the court concluded that Atomberg failed to demonstrate novelty or originality in its registered design. Justice Godse emphasized that for a design infringement claim to succeed, there must be a clear demonstration of novelty and distinctiveness in the registered design, which was not evident in this case. The court noted that the alleged similarities between the fans were insufficient to establish an actionable claim, as the plaintiff compared the defendant's fan with its subsequent models rather than the registered design itself.
The court further observed that the plaintiff's evidence, including comparative tables and photographs, did not convincingly establish any unique or novel features that could be considered obviously different from standard ceiling fan designs. The court also found no substantial evidence of goodwill or distinctiveness specific to the registered design, which is essential for a passing off claim.
In its defense, Stove Kraft Limited highlighted the lack of novelty in Atomberg's design, stating that the plaintiff's design was merely a trade variant without unique characteristics. The court agreed, noting visible differences between the registered design and the defendant's fan, and concluded that there was no prima facie case of design infringement or passing off.
Given the absence of a prima facie case, balance of convenience, or potential irreparable loss, the court dismissed the interim application and ordered the release of the defendant's seized goods.
Bottom Line:
Designs Act, 2000 - Interim relief sought for design infringement and passing off - Plaintiff must establish prima facie case of novelty, originality, and goodwill specific to the registered design - Mere similarity between products insufficient; actionable claim requires "something more" than similarity.
Statutory provision(s): Designs Act, 2000 Sections 4(a), 15(b), 19, 22(2), 22(3)
Atomberg Technologies Private Limited v. Stove Kraft Limited, (Bombay) : Law Finder Doc id # 2884783
