The Court emphasizes the necessity of establishing jurisdiction before granting interim relief in patent infringement cases.
In a significant ruling, the Himachal Pradesh High Court has vacated an interim injunction against Safex Chemicals Private Limited, initially granted in a patent infringement case brought by SML Limited. The Division Bench, comprising Chief Justice Gurmeet Singh Sandhawalia and Justice Bipin Chander Negi, delivered the judgment on June 4, 2026, highlighting the critical importance of territorial jurisdiction in legal proceedings, even at the stage of granting interim relief.
The case revolved around allegations by SML Limited that Safex Chemicals, along with another defendant, had infringed upon a patent owned by SML. The primary contention of Safex Chemicals was the lack of territorial jurisdiction of the Himachal Pradesh High Court to entertain the suit, as detailed in their appeal against the interim injunction.
The appellant argued that no authorized sale of the allegedly infringing product, branded "Aladdin," occurred within the jurisdiction of the Himachal Pradesh Court. They contended that any sale within the state was unauthorized and orchestrated by the plaintiff to establish jurisdiction improperly.
In its judgment, the Court reiterated that territorial jurisdiction must be assessed based on prima facie satisfaction derived from the plaint, written statements, and applicable laws. The Court found that the documents presented did not substantiate claims of any manufacturing or authorized sales activity by Safex Chemicals within the jurisdiction. The evidence submitted, including invoices, was deemed insufficient to establish a legitimate cause of action within Himachal Pradesh.
The Court also referenced various precedents, including the Supreme Court's decision in Asma Lateef v. Shabbir, underscoring the necessity of jurisdictional verification before granting interim relief. It emphasized that a single act of infringement could justify jurisdiction under the Patents Act, provided it is supported by authentic and fair transactions.
The decision underscores the judiciary's role in ensuring that legal processes respect jurisdictional boundaries, thereby preventing parties from being drawn into litigation without proper cause. The vacating of the interim injunction signifies the Court's acknowledgment of the appellant's argument that the jurisdictional claims were not substantiated adequately.
This ruling serves as a crucial reference for future cases, stressing the importance of establishing a clear jurisdictional basis before proceeding with interim relief in patent and other intellectual property disputes. The case has been remanded for further proceedings consistent with this judgment.
Bottom line:-
Territorial jurisdiction is of critical importance even when considering an interim relief. A prima facie satisfaction of jurisdiction must be recorded by the court before granting interim injunction.
Statutory provision(s):
- Civil Procedure Code, 1908: Section 19, Section 20(c), Order 39 Rules 1 and 2
- Patents Act, 1970: Section 48
Safex Chemicals Private Limited v. SML Limited, (Himachal Pradesh)(DB) : Law Finder Doc id # 2915063
