Bajaj Auto Ltd. vs. T.V.S. Motor Company Ltd.
Case Overview:
- Citation: Civil Appeal No. 6472 of 2004
- Judges: Justice B.N. Agarwal & Justice P.P. Naolekar
- Court: Supreme Court of India
Case Timeline:
- October 2007: Bajaj Auto accused TVS of patent infringement at the Madras High Court.
- Temporary Injunction: Bajaj sought a temporary injunction while the case was pending.
- Groundless Threat Suit: TVS countered with a lawsuit against Bajaj for baseless infringement threats.
- February 2007: Madras High Court granted a temporary injunction to Bajaj.
- May 2009: The Division Bench of the Madras High Court lifted the temporary injunction.
- Supreme Court Appeal: Bajaj appealed the decision to the Supreme Court.
- Settlement: The parties settled out of court, withdrawing all pending suits and reaching an agreement.
Relevant Laws:
- Sections 64, 106, 107, and 108 of the Patents Act, 1970
Case Details: Two main lawsuits were involved. Bajaj Auto Limited filed a suit in the Madras High Court under Section 108 of the Patents Act, 1970, seeking a permanent injunction to prevent TVS from using its patented 125-CC Flame engine technology. Bajaj argued that TVS’s CCVTi technology in the 125-CC Flame engine was essentially a copy of its DTS-i technology, barring a three-valve difference.
While this was ongoing, Bajaj sought a temporary injunction. TVS filed a counter-suit under Section 106 of the Patents Act, alleging groundless threats of infringement. The temporary injunction granted to Bajaj halted TVS’s production and pending orders. TVS successfully appealed to lift the injunction, leading Bajaj to appeal to the Supreme Court.
Key Issues:
- Did TVS infringe Bajaj’s patent?
- Can improvements on patented technology be used without infringing the original patent?
Court’s Analysis: Bajaj claimed its patented technology was innovative and not prior art, thus deserving protection. It highlighted that its technology was commercially successful before TVS introduced its product.
TVS argued that the technology was prior art, citing a US Honda patent, and should not have been patented by Bajaj. TVS’s design, which included two spark plugs with three valves, was licensed and differed from Bajaj’s two-valve design. They also referenced the Bishwanth Prasad Radhey Shyam v. H.M. Industries case, arguing that Bajaj’s invention was neither new nor novel.
The Supreme Court was displeased with the delays in the Madras High Court and emphasized the need for speedy resolutions in intellectual property cases. It ordered TVS to file a written statement promptly and directed the Madras High Court to hear the case daily until resolved, without adjournments, aiming for resolution by November 30, 2009. A receiver was appointed to monitor TVS’s sales during the suit.
Conclusion: The Supreme Court’s decision emphasized the importance of swift resolution in intellectual property disputes. It provided guidelines for lower courts to prioritize these cases, mandating daily hearings and timely resolution. This judgment sets a precedent for the expedited handling of intellectual property cases, benefiting IPR owners and the international community.
