Inox India Ltd. sued Cryogas Equipment Pvt. Ltd. and LNG Express India Pvt. Ltd. for alleged copyright infringement of their proprietary engineering drawings. These drawings were used in the design and manufacture of cryogenic storage tanks and LNG distribution systems. Inox claimed that its technical drawings were ‘artistic works’ under the Copyright Act, 1957. However, the Defendants argued that these drawings, being used for industrial manufacturing and mass production, were actually ‘designs’ as per the Designs Act, 2000. Thus as per Section 15(2) of the Copyright Act, if the work is not registered as a design and has been reproduced more than fifty times, copyright protection cannot be claimed.
On an appeal filed by Cryogas Equipment Pvt. Ltd. and LNG Express Pvt. Ltd., the Bench, comprising of Justice Surya Kant and Justice N. Kotiswar Singh, held that the Commercial Court rejected Inox’s suit without trial. Especially, since the matter raised complex and triable issues. With reference to the interplay between copyright and design law in India, the Court laid down a two-pronged test – firstly, to determine if the work is a pure artistic work or a design applied industrially and secondly, to assess if the work’s dominant purpose is functional utility. The Supreme Court clarified that copyright cannot be used to secure perpetual protection for mass-produced industrial designs, which must be registered under the Designs Act, 2000. The Court dismissed the appeal and restored Inox’s suit for trial, and directed the Commercial Court to decide the interim injunction within two months and complete the trial within a year.
Source: Cryogas Equipment Pvt. Ltd. and LNG Express India Pvt. Ltd. v. Inox India Ltd. [C.A.No.005174-005174/2025]