Summary
In the case of M/s Sunhok Wheels Pvt. Ltd. & Ors. vs The State of West Bengal & Ors., the Calcutta High Court held that vehicle registration cannot be denied solely on the basis of a pending patent dispute. The court ruled that unless the vehicles are identical to those in the pending civil suits and provided that all statutory conditions under the Central Motor Vehicles Rules are met, registration must be allowed.
Patent Rights and Vehicle Registration Dispute
The petitioners, who manufacture e-rickshaws, challenged the refusal of registration for their vehicles by the registering authority in West Bengal. The refusal stemmed from internal instructions within the Transport Department, which cited an earlier High Court direction and a private party’s claim of holding a patent over the e-rickshaw technology.
The private respondent had ongoing civil suits asserting exclusive rights under a patent and objected to registration of similar vehicles by others.
Questions Before the Court
- Whether a patent claim or pending civil suit can bar vehicle registration under the Motor Vehicles Act and Rules.
- Whether the registering authority is justified in refusing registration without examining whether the vehicles are distinct from those in the patent dispute.
Arguments Presented By the Parties
Petitioners
The petitioners argued that the registration of their vehicles was being arbitrarily blocked due to a private party’s patent claim. They stated that the refusal lacked statutory basis and that they had complied with all conditions under the Motor Vehicles Act and Rules, including the requirements of Rule 126.
Respondents (State Authorities and Private Respondent)
The State relied on internal memos and the private party’s assertion of patent rights. The private respondent cited an earlier Division Bench order acknowledging the patent claim and asserted that any manufacturer must obtain a licence from them.
Court’s Analysis of Patent and Vehicle Registration Interface
The court said that patent rights and vehicle registration operate in separate legal domains. According to the court, the existence of a patent claim does not, by itself, restrict statutory functions of registering authorities under the Motor Vehicles Act.
The court referred to an earlier Division Bench order which vacated a stay on registration and held that whether the private respondent has an enforceable patent right and is entitled to compensation are factual issues to be decided in pending civil suits. The court observed that registration cannot be restrained unless the vehicles in question are the same as those in the suit.
The court stated that the registering authority must process registration applications based on compliance with statutory requirements, particularly Rule 126 of the Central Motor Vehicles Rules, 1989, which relates to vehicle type approval and certification.
As per the court, the registration authority cannot enforce patent rights or adjudicate patent disputes. Its role is limited to ensuring compliance with the vehicle laws and verifying whether the vehicles are different from those forming the subject of the civil suit.
Findings
The court directed that e-rickshaws manufactured by the petitioners be registered, provided:
- The vehicles are different and distinct from those forming the subject matter of the pending suit before the Additional District Judge, 13th Court, Alipore.
- All statutory conditions under Rule 126 of the Central Motor Vehicles Rules and other applicable provisions are fulfilled.
Relevant Paras
“…there is no restriction for registration of the e-rickshaws/e-vehicles provided the vehicles are different and distinct from the category forming subject matter of the title suit… and subject to the compliance of Rules 126 of the Central Motor Vehicles Rules, 1989 and all other formalities prescribed under the governing Act/Rules…”
Case Citation
M/s Sunhok Wheels Pvt. Ltd. & Ors. vs The State of West Bengal & Ors., WPA No. 22027 of 2025, decided on 24 October 2025.
Indian Kanoon Link: http://indiankanoon.org/doc/167576733/ (Visited on 23 December 2025)
Disclaimer
This case blog is based on the author’s understanding of the judgment. Understandings and opinions of others may differ. An AI application was used to generate parts of this case blog. Views are personal.