Cryogas Equipment Private Limited v. Inox India Limited and Others; LNG Express India Private Limited v. Inox India Limited and Others

This case involves a dispute over copyright infringement concerning engineering drawings for cryogenic storage tanks and semi-trailers. The original plaintiff, Inox India Limited, claimed copyright in its proprietary engineering drawings and literary works. The defendants, Cryogas and LNG Express, argued that the drawings were designs registrable under the Designs Act and had lost copyright protection due to industrial application. The Supreme Court established a two-pronged test to distinguish between 'artistic work' under the Copyright Act and 'design' under the Designs Act, emphasizing the 'functional utility' of the article. The Court ultimately upheld the High Court's decision, which had set aside the Commercial Court's order to reject the plaint, thereby allowing the suit to proceed to trial. Result: Appeals against High Court's decision dismissed; High Court's rejection of Order VII Rule 11 application upheld; Commercial Court directed to conduct trial and decide interim injunction application.