Court rules in favor of Orient Electric, restraining Crompton Greaves from further sales of infringing ceiling fans.
In a significant judgment delivered by the Delhi High Court, Justice Tushar Rao Gedela has granted an interim injunction in favor of M/s. Orient Electric Limited against Crompton Greaves Consumer Electricals Limited, restraining the latter from manufacturing and selling ceiling fans that infringe upon Orient Electric's registered design. The case, titled "M/s. Orient Electric Limited v. Crompton Greaves Consumer Electricals Limited," was adjudicated under the provisions of the Designs Act, 2000.
Orient Electric, a part of the multinational conglomerate CK Birla Group, had filed for an interim injunction to protect its registered design for the 'Aeon' series of ceiling fans. The plaintiff claimed that Crompton Greaves had launched a new range of fans under the 'GRACE' series, which allegedly copied the dominant visual features of the 'Aeon' series.
The court's decision focused on several key aspects of design law. It was argued by Orient Electric's legal counsel, Mr. Abhishek Malhotra, that the novelty of the 'Aeon' fan series resided in its unique combination and visual arrangement of known elements, which are protected under the Designs Act. The court agreed with this assessment and highlighted that the design must be assessed as a whole, thereby rejecting Crompton Greaves' defense that attempted to challenge the validity of the design by combining individual elements from prior designs.
The court emphasized that mosaicing of prior art designs is impermissible and that novelty cannot be attacked by combining individual elements of prior designs. Justice Gedela observed that none of the prior arts cited by Crompton Greaves disclosed all the features of Orient Electric's design. The judgment also noted that Crompton Greaves had not provided any prior art that, as a whole, matched or mapped with the registered design of Orient Electric.
In addition to the design infringement, the court considered the issue of the launch date of the infringing product. Despite assertions by Crompton Greaves that the product was launched before the injunction application, evidence showed misleading statements regarding the launch dates. Consequently, the court directed Crompton Greaves to maintain records of sales and financial statements related to the infringing product.
The interim injunction restrains Crompton Greaves and associated parties from manufacturing, marketing, or selling ceiling fans that infringe upon Orient Electric's design, specifically the 'Aeon' series. The court has ordered Crompton Greaves to cease further sales of the infringing product, except those already sold, and to disclose sales records in a sealed affidavit.
This ruling underscores the importance of respecting registered designs and the legal protections afforded to original creators under the Designs Act. The case is scheduled for further hearing on July 17, 2026.
Bottom line:-
Designs Act, 2000 - Mosaicing of prior art designs is impermissible - Novelty cannot be attacked by combining individual elements of prior designs - Interim injunction granted against defendant for manufacturing and selling infringing ceiling fans, as plaintiff's registered design found to be novel and original.
Statutory provision(s): Designs Act, 2000 - Sections 2(d), 4(c), 19, 22
