Summary
Orient Electric Limited, maker of the AEON ceiling fan series, accused Crompton Greaves Consumer Electricals Limited of copying its registered design in Crompton’s new GRACE range. Crompton argued the AEON design was an unoriginal mosaic of features drawn from several earlier fan designs, while Orient maintained that a design must be judged as an integrated whole, not dissected into parts. The Delhi High Court, applying settled principles against combining prior art to attack novelty, found that Crompton had not proven invalidity and that the GRACE fans replicated the AEON design’s essential features. The ruling matters because it confirms that a registered design can still be enforced through an interim injunction even after the accused product has reached the market, particularly where the defendant’s own account of its launch date does not hold up.
Background
A design registered on paper counts for little if a court will not stop a rival product once it has reached store shelves. A recent ceiling fan design infringement dispute before the Delhi High Court tested exactly that proposition, asking whether a two-year-old design registration could still halt a fan already sold across four states.
Orient Electric Limited (“Orient”), part of the CKA Birla Group and a fan manufacturer under the “Orient” mark since 1954, holds registered design no. 393299-001 for its “AEON” ceiling fan series, granted under the Designs Act, 2000 (“Designs Act”) in April 2024 after roughly two years of research and development costing about Rs. 2 crore. Orient launched the AEON series in May 2024, registered a variant in January 2025, and by March 2026 had recorded cumulative AEON sales of about Rs. 88 crore. Orient claimed that Crompton Greaves Consumer Electricals Limited (“Crompton”), a century-old rival, copied the AEON design’s tapered blades, compact hub and sculptural silhouette in its new “GRACE” range, sold under the “Energion Grace” name.
Orient sued for infringement and sought an interim injunction. At the first hearing, Crompton’s counsel stated the GRACE fans had already launched across four states by 20 March 2026, backed by an affidavit and photographs. Only later, through invoices filed on Crompton’s own application, did it emerge that retail sales had actually begun on 6 April 2026, after that hearing. The court reserved orders on 6 May 2026 and ruled on 14 May 2026.
Questions Before the Court
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- Whether Orient’s registered design no. 393299-001 lacked novelty and originality under Section 4(c) of the Designs Act by being a “mosaic” of features drawn from multiple prior published fan designs.
- Whether Crompton’s “GRACE” series reproduced the features that give the AEON design its novelty, amounting to piracy under Section 22 of the Designs Act.
- Whether an interim injunction could still be granted once the allegedly infringing product had already been launched and sold in the market.
- Whether Crompton’s shifting account of its own launch date affected the balance of convenience on the injunction application.
Orient’s Arguments
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- The AEON design’s novelty lies in the “shape and configuration” of the fan as a whole, protected under Section 2(d) of the Designs Act, not in any single element viewed in isolation.
- Design infringement must be assessed by comparing the two designs as complete, integrated wholes, relying on the anti-mosaicing principle drawn from TTK Prestige Ltd. vs. KCM Appliances Pvt. Ltd. (CS(COMM) 697/2022).
- None of Crompton’s seven cited prior-art references disclosed the AEON design in its entirety; each showed, at most, an isolated feature such as blade shape or hub form.
- Crompton’s own affidavits and invoices showed the GRACE fans were not actually sold until 6 April 2026, contradicting its earlier statement that sales began on 20 March 2026.
Crompton’s Arguments
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- A ceiling fan offers little scope for original design, so the AEON registration could not claim meaningful novelty.
- The AEON design merely combined features already present in at least seven prior published designs, making it a prohibited combination of known designs under Section 4(c).
- The registration was itself suspect, entitling Crompton to raise invalidity as a defence under Section 19 of the Designs Act.
- Crompton had over a century of standing in the market and no motive to imitate a competitor’s design.
Court’s Analysis and Observations
The Design Must Be Judged as a Whole
The court noted that a registered design has to be compared against alleged prior art, and against an allegedly infringing product, as a complete and integrated whole rather than as a collection of separable features. Drawing on the reasoning in TTK Prestige Ltd. vs. KCM Appliances Pvt. Ltd., the court observed that Section 2(d) of the Designs Act protects only the visual features of shape, configuration, pattern or ornament as they appear on a finished article, and that no single element can be isolated for comparison while ignoring the composite impression the article creates. This framework proved decisive in the ceiling fan design infringement dispute, since Crompton’s defence rested entirely on dissecting the AEON fan into individual components.
Mosaicing Prior Art Cannot Defeat Novelty
The court held that Section 4(c) bars registration only of a design that is a combination of already known designs, not a design that borrows individual, unprotected features from several sources and arranges them in a new way. The court found that Crompton’s seven cited prior-art references, taken separately, showed at best isolated elements such as blade shape or hub form, and that none of them, viewed as a single document, disclosed the AEON design’s overall configuration. The court reasoned that mosaicing, stitching together fragments from different prior publications to attack novelty, is impermissible, and that the burden of proving invalidity therefore remained undischarged by Crompton.
An Instructed Eye Finds Piracy in the Details
The court observed that infringement had to be assessed through the eyes of an “instructed” observer, familiar with the prior art and alert to which features actually gave the AEON design its distinctiveness. On physically examining both fans, the court found that the blade profile, the curve at the motor end, and the fluidic line of the bottom cover were substantially replicated in the GRACE fans, with only the canopy shape showing minor variation. The court stated that such peripheral differences could not shield a design that otherwise reproduced the essential novel features, reinforcing why this ceiling fan design infringement claim succeeded on a visual comparison of the two products.
Conduct Before the Court Tips the Balance
The court further observed that an interim injunction is not automatically barred merely because the impugned product has already reached the market. The court found that Crompton’s own affidavits and invoices contradicted its earlier statement that the GRACE fans were sold from 20 March 2026, since dispatch to warehouses began only in early March while retail sales in fact commenced on 6 April 2026, after the first hearing. The court opined that this unexplained inconsistency weighed against Crompton on the balance of convenience and reinforced the case for interim relief notwithstanding the product’s presence in stores.
Findings
In view of the observations and the arguments presented by both the parties, the Delhi High Court held that:
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- Orient’s registered design no. 393299-001 for the AEON fan series was validly registered, and Crompton failed to prove invalidity based on prior publications.
- Combining isolated features from multiple prior-art documents to attack novelty is impermissible under Section 4(c) of the Designs Act.
- Crompton’s “GRACE” (Energion Grace) fans replicated the essential novel features of the AEON design, amounting to piracy under Section 22 of the Designs Act.
- Crompton and its distributors, dealers and agents stood restrained from manufacturing, marketing or selling the GRACE series, or any deceptively similar design, including online, from the date of the order.
- Crompton was directed to disclose, under sealed cover, its GRACE sales and financial records from 6 April 2026 onward, within four weeks.
- The findings were confined to the interim application and would not affect the final merits of the suit.
Case Citation: M/S. Orient Electric Limited vs. Crompton Greaves Consumer Electricals Limited, CS(COMM) 331/2026, Delhi High Court, decided on 14 May 2026. Available at http://indiankanoon.org/doc/151811666/.
Authored by Gaurav Mishra, Patent Attorney, BananaIP Counsels