Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Intellectual Property LawSupreme Court of India

Atomberg Technologies Private Limited vs Eureka Forbes Limited & Anr.

Not available · 2025 INSC 1253Decided 17 Oct 2025
Not available
Justice Pamidighantam Sri Narasimha · Justice Atul S. Chandurkar

Background

Atomberg Technologies launched a water purifier and was allegedly warned by a competitor, Eureka Forbes, that the product infringed Eureka Forbes's patents: warnings Atomberg says were made "groundlessly" to its own distributors, causing it business harm. Atomberg sued Eureka Forbes for these "groundless threats" in the Bombay High Court on 1 July 2025. Six days later, Eureka Forbes sued Atomberg for actual patent infringement in the Delhi High Court, basing Delhi's jurisdiction on the fact that Eureka Forbes had bought and had a sample of Atomberg's product delivered there. Each side then asked the Supreme Court to transfer the other's suit to their own preferred city, so both disputes could be heard together.

Decision Breakdown

The Supreme Court held that a suit for "groundless threats" of patent infringement (under Section 106 of the Patents Act, 1970) is a legally independent cause of action from a suit for actual infringement, since Parliament deliberately removed a proviso (present in the old 1911 law) that would have barred a groundless-threats suit whenever a real infringement suit was also pending. The Court found that the Bombay suit was filed first, the parties had their registered offices in Mumbai, and the two suits raised substantially overlapping facts and legal issues about the same product, creating a real risk of two courts reaching conflicting conclusions on the same set of facts. Applying precedent that overlapping suits with common issues should be tried together to avoid duplicated evidence and inconsistent decrees, the Court transferred Eureka Forbes's Delhi infringement suit to the Bombay High Court to be heard alongside Atomberg's suit, and dismissed Eureka Forbes's competing request to move the Bombay suit to Delhi.

Lesson Learnt

When two closely related lawsuits between the same parties over the same underlying dispute are filed in different High Courts, the Supreme Court can and will consolidate them in one court, generally favoring the court where the earlier suit was filed, to avoid wasted judicial time and the risk of contradictory verdicts.

Atomberg Technologies Private Limited vs Eureka Forbes Limited & Anr. – Legal Case Shots | LegalAware