OpenTV Inc. v. The Controller of Patents and Designs and Anr

This case involves an appeal against the refusal of a patent application for a "system and method to provide gift media." The Controller of Patents denied the patent on grounds that the invention constitutes a non-patentable business method under Section 3(k) of the Patents Act, and that proposed claim amendments were impermissible. The court reviewed whether claims can be amended during appeal and if the invention is indeed a business method. It determined that while amendments are generally allowed if they don't broaden the scope, the core invention here is a business method, explicitly excluded from patentability in India. The court emphasized that the mere technical implementation of a business method does not make it patentable. Result: Appeal for patent grant dismissed; the invention was deemed a non-patentable business method.