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Cryogas Equipment Private Limited v. Inox India Limited and Others

Civil Appeal · 2025 INSC 483Decided 15 Apr 2025
Civil Appeal (arising out of SLP(C) No. 28062 of 2024), with connected appeal by LNG Express India Private Limited (SLP(C) No. 28017 of 2024)
Justice Surya Kant · Justice Nongmeikapam Kotiswar Singh

Background

Inox India Limited sued Cryogas Equipment and LNG Express India, alleging they had copied Inox's proprietary engineering drawings and related technical write-ups used to design and manufacture parts of cryogenic storage tanks and transport trailers for industrial gases and LNG. The defendants got the suit thrown out at a preliminary stage by the Commercial Court at Vadodara, arguing that copyright in such drawings could not survive because Inox had commercially reproduced the design more than fifty times through an industrial process: a specific bar under Section 15(2) of the Copyright Act meant to push such designs into the Designs Act regime instead. The Gujarat High Court restored the suit, holding this issue could not be resolved without a trial, and the defendants appealed to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the High Court and dismissed the appeals, agreeing that whether the drawings amount to a "design" excluded from copyright protection under Section 15(2) is a mixed question of law and fact that cannot be decided on a preliminary application (Order VII Rule 11 CPC) without evidence. It held that at the stage of testing whether a plaint discloses a cause of action, courts must not conduct a mini-trial on contested facts, and that since the suit also raised separate claims over literary works, confidential information and know-how (independent of the copyright-versus-design question), the plaint could not be thrown out even partially. The Court directed the Commercial Court to decide the pending interim-injunction application within two months and to complete the trial, applying a simplified analytical test to determine the true nature of the drawings, within one year.

Lesson Learnt

A lawsuit cannot be dismissed at the threshold merely because one of several legal theories in it looks weak or contested. If genuine factual disputes exist (here, whether the drawings are "artistic works" or industrially-reproduced "designs"), the case must go to trial rather than being decided on the pleadings alone.

Official source (sci.gov.in)View Judgment (PDF)

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