Court holds Suit Patents valid and novel; restrains defendant from manufacturing and selling tampering-evident and leak-proof packaging products infringing Mold-Tek’s patents
In a significant ruling dated April 30, 2026, the Delhi High Court, presided over by Justice Tejas Karia, granted an interim injunction in favor of Mold-Tek Packaging Limited ("Plaintiff") in a patent infringement suit against Pronton Plast Pack Pvt. Ltd. ("Defendant"). The Court restrained the Defendant and its associates from manufacturing, selling, or dealing in products that infringe on two key patents owned by Mold-Tek related to tamper-evident leak-proof packaging systems.
The suit centered on Indian Patent Nos. 401417 ("Suit Patent I") and 298724 ("Suit Patent II"), which protect innovative tamper-evident leak-proof pail closure systems and tamper-proof lids with spouts for containers, respectively. Mold-Tek alleged that Pronton Plast Pack’s product line, including plastic containers, pails, drums, and lids, were infringing these patents by copying the patented features.
Detailed examination of the patents and the allegedly infringing products revealed that Suit Patent I claims a tamper-evident lid with unique features such as a tear band that extends continuously around the lid, a secondary locking section with protrusions engaging spring-back hinges of the container, and a specialized inverted U-shaped peripheral channel that ensures leak-proof closure and load transfer during stacking. Suit Patent II pertains to a tamper-proof lid with a leak-proof spout assembly characterized by an "M"-shaped contour and a tail ring folding mechanism that secures the spout base to the main lid, ensuring leak-proof and tamper-proof sealing.
The Defendant raised a "Gillette Defense," claiming its products adhered to prior art, notably a prior patent (D1) disclosing a tamper-evident container lid attached by a hinge mechanism and tear band opening from three sides. However, the Court rejected this defense, holding that the Defendant’s products fell within the scope of Mold-Tek’s patent claims. The Court emphasized that minor differences, such as the tear band opening on three sides instead of all four, do not avoid infringement under the "pith and substance" doctrine. Additionally, the Defendant’s reliance on a prior "Ceased Patent" was held insufficient to invalidate the Suit Patents, as the patents in question contained novel and inventive features absent in the prior art.
The Court also noted the Defendant’s failure to "clear the way" by challenging the validity of the patents through pre-grant or post-grant opposition or revocation proceedings before launching its products, which weighed in favor of granting the injunction. Further, evidence was found of the Defendant’s CEO’s prior connection with Mold-Tek’s authorized distributor, raising suspicion of mala fide intent to exploit Mold-Tek’s proprietary technology.
On the balance of convenience and irreparable harm, the Court held that Mold-Tek would suffer irreparable injury if interim relief was denied, given the Defendant’s ongoing infringement and the Plaintiff’s substantial commercial success with the patented products.
Consequently, the Court granted an interim injunction restraining the Defendant and its affiliates from manufacturing, selling, or dealing in products infringing Mold-Tek’s Suit Patents I and II during the pendency of the suit, thereby protecting the Plaintiff's intellectual property rights.
This judgment underscores the judiciary’s commitment to safeguarding patent rights and deterring unauthorized exploitation of patented innovations in India’s competitive packaging industry.
Bottom line:-
Intellectual Property Law - Interim injunction granted in favor of the Plaintiff for the infringement of Suit Patents related to tamper-evident and leak-proof packaging systems - Defendant restrained from manufacturing and selling products infringing the patents in question.
Statutory provision(s):
Patents Act, 1970 Section 104, Code of Civil Procedure, 1908 Order XXXIX Rules 1 and 2, Section 151, Order XXXIX Rule 4
Mold-Tek Packaging Limited v. Pronton Plast Pack Pvt. Ltd., (Delhi) : Law Finder Doc id # 2892934
