Delhi High Court Denies Toyota’s Patent Injunction Plea Against LMW as Patent Expires

Delhi High Court Denies Toyota’s Patent Injunction Plea Against LMW as Patent Expires: NEW DELHI, India – In a significant development for India’s industrial landscape and intellectual property rights, the Delhi High Court has dismissed a plea by Japanese multinational Kabushiki Kaisha Toyota Jidoshokki (Toyota) seeking an interim injunction against Indian company LMW Limited. The dispute centered on the alleged infringement of a patent related to spinning machines used in yarn production. The Court’s decision, delivered by Justice Saurabh Banerjee on July 1, hinged critically on the fact that Toyota’s patent had already expired.

The case, titled Kabushiki Kaisha Toyota Jidoshokki v. LMW Limited, saw Toyota filing an application under Order XXXIX, Rule 1 and Rule 2 of the Code of Civil Procedure (CPC). The Japanese giant sought to restrain LMW from using its ‘Spinpact’ product or any other technology that allegedly infringed upon Toyota’s patent, identified as IN759. This patent, according to Toyota, pertained to a fibre bundle concentrating apparatus positioned downstream of a draft machine in a spinning frame, a crucial component in modern yarn spinning machines. Toyota asserted that it actively markets and sells yarn spinning machines incorporating this patented technology.

However, Justice Banerjee, in his order, noted a pivotal detail: “In view of the aforesaid analysis and reasoning, it is clear that since IN759 has already expired on 24.05.2025, this Court is precluded from passing any effective order restraining infringement of the said patent. As such, any finding on the merits by this Court would be a nullity and are likely to prejudice the fate of the present proceedings.” This effectively rendered any injunction request futile, as the patent is now freely available in the public domain with no provision for renewal.

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Despite denying the injunction, the Court did issue a directive to LMW. It instructed the Indian company to submit its financial details pertaining to the period during which it allegedly used the features of the invention in question, up until the patent’s expiry. This information is to be filed in a sealed cover, accessible to Toyota only under further orders of the Court, ensuring that the ongoing proceedings regarding other rights and contentions are not prejudiced.

LMW, in its defense, contended that it is not a “fly-by-night operator” and asserted that it had acquired the know-how for the technology through a German company, developing its own version even before Toyota’s patent. The Indian firm further argued that Toyota’s patent lacked novelty and inventive step, claiming that the technology was conventionally known and already in the public domain, having been disclosed in prior arts.

The Court, after considering the arguments, concurred that with the patent’s expiry, the technology is now publicly accessible. While acknowledging that Toyota might have a prima facie case, with the balance of convenience in its favor and a likelihood of irreparable harm, loss, and injury, Justice Banerjee emphasized that “the fact of expiry of the patent of the plaintiff is a crucial factor which would decide the fate of the present application.”

Toyota was represented in court by Senior Advocate Chander M Lall, instructed by a team from Anand and Anand, including advocates Pravin Anand, Archana Shanker, Sagar Arora, Annanya Mehan, and Ashutosh Upadhyaya. LMW’s defense was led by Senior Advocate Gaurav Pachnanda, instructed by a team from Remfry and Sagar, comprising advocates Vineet Rohilla, Pankaj Soni, Debashish Banerjee, Ankush Verma, Rohit Rangi, and Namrata Sinha.

This ruling underscores the time-bound nature of patent protection and serves as a reminder that legal remedies for infringement are intrinsically tied to the active life of a patent. While the immediate injunction was denied, the Court’s directive for LMW to submit financial details indicates that the broader implications of the alleged infringement during the patent’s validity period may still be subject to further adjudication.

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READ ORDER:Kabushiki Kaisha Toyota Jidoshokki vs LMW Limited Order