Summary
In the case of Kabushiki Kaisha Toyota Jidoshokki v. LMW Limited, the plaintiff sought interim relief for alleged infringement of its expired patent. The Court declined to interfere. It held that once a patent expires, its subject matter enters the public domain, and the right to seek protection ceases to exist.
Background and Facts
Toyota Jidoshokki, a Japanese textile machinery manufacturer, owned Indian Patent No. 244759, titled “Fiber Bundle Concentrating Apparatus in Spinning Machine.” The patent was filed in May 2005 and granted in December 2010. It expired on 24 May 2025 upon completion of the 20-year statutory term.
The invention in the patent related to cotton fly accumulation in spinning machines by introducing grooves of specified depth, 0.04 mm or more, on the bottom nip roller. These grooves, the patentee claimed, reduced machine downtime and improved yarn quality.
Toyota brought a suit for infringement against LMW, alleging unauthorized use of its patented technology in the Spinpact machine. According to Toyota, measurements showed the grooves on LMW’s rollers were 0.15 mm deep, which fell within the scope of Claim 1. In the suit, Toyota sought interim relief restraining further sale or use of the impugned product.
Issue for the Court
The principal question before the Court was whether interim relief could be granted to enforce a patent that had expired during the pendency of the application.
Key Arguments
Toyota argued that LMW had implemented the claimed feature without a license or authorization. It relied on physical samples, third-party lab reports, and the absence of any pre- or post-grant challenge by LMW.
LMW responded that the patent had expired. It argued that once the patent expires, no right remains to be enforced, whether through interim or final relief. LMW also raised challenges to the patent’s validity, asserting a lack of novelty and inventive step.
Court on Injunction after Patent Expiry
The Court confined its analysis to the legal effect of expiry. It stated that under Section 53(1), every patent granted after the 2002 amendment lasts for twenty years from the filing date. As per the Court, Section 53(4) is categorical: upon expiry, the patent ceases to have effect, and the subject matter becomes free for public use.
It further stated that the statutory term is final and that it cannot be extended, directly or indirectly. It said that injunctive relief is designed to protect subsisting rights, and when the right itself no longer exists, no injunction can be granted.
The Court declined to evaluate whether LMW had used the claimed features or whether Toyota had made out a prima facie case. It found that those questions had become academic once the patent lapsed, because the legal right, and with it the cause of action for interim protection, had extinguished.
Findings and Order
The Court dismissed the application under Order XXXIX Rules 1 and 2 of the CPC. It held that once Indian Patent No. 244759 expired on 24 May 2025, Toyota no longer had enforceable rights because the claimed invention had entered the public domain. The Court therefore refused to grant an injunction.
Relevant Paragraphs
Paragraph 39: “…the term of every patent… shall be twenty years from the date of filing of the application… after expiration… the said patent shall cease to have effect.”
Paragraph 40: “No patent holder… can be allowed to claim a lifetime monopoly… granting an injunction… would lead to anomalies and in fact, be futile.”
Paragraph 41: “…once in public domain, everyone including the defendant… is/will be free to use… in any form whatsoever.”
Paragraph 42: “The plaintiff has lost its right to enforce the said IN759 after the expiry of the limited/mandatory period of twenty years.”
Disclaimer
This case note has been prepared based on the author’s understanding, views, and conclusions. Opinions of others may differ. Parts of this note have been generated using a proprietary AI technology.
Citation: Kabushiki Kaisha Toyota Jidoshokki v. LMW Limited, CS(COMM) 881/2024, Delhi High Court, decided on 1 July 2025. Available at: http://indiankanoon.org/doc/167660632/ (last visited 4 August 2025).
