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.<\/p>\n
Orient Electric Limited (\u201cOrient\u201d), part of the CKA Birla Group and a fan manufacturer under the \u201cOrient\u201d mark since 1954, holds registered design no. 393299-001 for its \u201cAEON\u201d ceiling fan series, granted under the Designs Act, 2000 (\u201cDesigns Act\u201d) 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 (\u201cCrompton\u201d), a century-old rival, copied the AEON design\u2019s tapered blades, compact hub and sculptural silhouette in its new \u201cGRACE\u201d range, sold under the \u201cEnergion Grace\u201d name.<\/p>\n
Orient sued for infringement and sought an interim injunction. At the first hearing, Crompton\u2019s 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\u2019s 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.<\/p>\n
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.<\/em>, 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\u2019s defence rested entirely on dissecting the AEON fan into individual components.<\/p>\n 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\u2019s 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\u2019s 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.<\/p>\n The court observed that infringement had to be assessed through the eyes of an \u201cinstructed\u201d 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.<\/p>\n 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\u2019s 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\u2019s presence in stores.<\/p>\n In view of the observations and the arguments presented by both the parties, the Delhi High Court held that:<\/p>\nMosaicing Prior Art Cannot Defeat Novelty<\/strong><\/h3>\n
An Instructed Eye Finds Piracy in the Details<\/strong><\/h3>\n
Conduct Before the Court Tips the Balance<\/strong><\/h3>\n
Findings<\/h2>\n
\n
\n