Inox India Private Limited v. Cryogas Equipment Private Limited

Every founder who has ever shipped a physical product carries a quiet fear: that the very drawings which gave their invention life could one day be copied with impunity. The line between protected intellectual property and public domain is razor-thin, and nowhere is that line more treacherous than at the intersection of copyright and industrial design. The Gujarat High Court's decision in the dispute between Inox India Private Limited and Cryogas Equipment Private Limited pulls back the curtain on this exact tension, revealing a legal trapdoor that can swing open after just fifty units leave the factory floor.

Inox India Private Limited, a company dealing in specialized equipment for commercial vehicles, found itself in a commercial trademark dispute with Cryogas Equipment Private Limited. At the heart of the conflict were proprietary engineering drawings that Inox claimed as its own creative work. When Inox approached the Commercial Court to protect these drawings and seek an injunction against alleged infringement, the court dismissed the suit outright. The reason given was that the protection sought was barred under Section 15(2) of the Copyright Act, a provision that effectively cuts off copyright protection for certain designs once they are reproduced in industrial quantities beyond a specified threshold. Aggrieved by this rejection, Inox took the matter to the Gujarat High Court in appeal, arguing that its drawings deserved the full shield of copyright law.

Inox's central argument was that its engineering drawings were original artistic works, painstakingly created and embodying the creative labor of its design team. The company contended that these drawings should enjoy copyright protection as artistic works, independent of any registration under the Designs Act. On the other side, the Commercial Court's earlier reasoning, which Inox was challenging, leaned on Section 15(2) of the Copyright Act, which provides that once a design is applied to more than fifty articles by an industrial process, copyright in the design ceases to subsist. The legal friction was therefore clear: was the threshold of fifty units already crossed, stripping the drawings of copyright protection? And more fundamentally, were these engineering drawings artistic works at all, or were they industrial designs that had to be evaluated under a completely different legal framework?

The Gujarat High Court allowed Inox's appeal, setting aside the Commercial Court's order of dismissal. The Court made an important clarification: engineering designs may indeed be capable of registration under the Designs Act, but that does not automatically strip them of copyright protection. Copyright protection remains valid until the threshold limit specified in Section 15(2) of the Copyright Act is actually crossed. The Court emphasized that the nature of the design, whether it qualifies as an artistic work under copyright law or as an industrial process under design law, must be carefully examined on its own merits. Rather than accepting the blanket rejection, the High Court directed the Commercial Court to reconsider both the application for rejection of the plaint and the application for injunction simultaneously, giving Inox a fresh opportunity to establish its case.

For founders and IP professionals, this case delivers a sharp, practical lesson: do not assume that copyright protection for your engineering drawings vanishes the moment your product becomes commercially successful. The threshold under Section 15(2) of the Copyright Act is a specific numerical limit, and whether your drawings qualify as artistic works or industrial designs is a question that demands careful, fact-specific analysis. Before launching a product, audit your design documentation, understand exactly how many units have been produced, and consider complementary protection under the Designs Act. The difference between fifty units and fifty-one could be the difference between a enforceable copyright and a costly legal dead end.