Introduction:

Intellectual property law in India has long grappled with a deceptively simple question: when does one product’s design cross the line from inspiration to imitation?

The law of industrial designs, governed by the Designs Act, 2000, seeks to protect the visual and aesthetic identity of commercially produced articles, rewarding those who invest time, creativity and resources in developing novel and original designs.

Yet the boundary between legitimate competition and unlawful copying is often contested, particularly in industries where functional constraints naturally limit the scope of creative expression.

Industrial Design Protection in India

The ceiling fan industry presents precisely such a challenge. Fans, by their very functional nature, must rotate, must have blades, must have a motor housing and must be mountable from a ceiling.

This inherent functional constraint raises an important question — can a manufacturer claim proprietary rights over the aesthetic appearance of a ceiling fan when many of its visual elements are arguably dictated by function or have appeared in earlier products?

And when two competing fans look strikingly similar to the eye, how does a court decide whether that similarity is the result of copying or mere coincidence of design evolution?

Orient Electric vs Crompton Greaves Case Overview

The judgement delivered on May 14, 2026, by the High Court of Delhi in the case of Orient Electric Limited versus Crompton Greaves Consumer Electricals Limited provides a rich and detailed judicial examination of these questions.

The order grants an interim injunction restraining Crompton Greaves from selling its ‘GRACE’ series of ceiling fans on the ground that they prima facie infringe the registered design of Orient Electric’s ‘AEON’ fan series.

Key Issues Before the Delhi High Court

• Whether the design of the ceiling fan was original and novel.
• Whether functional elements can receive design protection.
• How courts should compare competing industrial designs.
• Whether prior art can be combined through mosaicing to invalidate a design.
• Whether an interim injunction can be granted after commercial launch.

Legal Significance of the Judgment

Beyond its immediate commercial significance, the judgement makes important contributions to the developing jurisprudence on design infringement in India, particularly on the permissibility of mosaicing prior art, the standard of visual comparison, and the circumstances in which a court may grant injunctions even after a product has been commercially launched.

Important Legal Principles Discussed

Legal Principle	Explanation
Design Infringement	Protection of the visual and aesthetic appearance of products under the Designs Act, 2000.
Functional Constraints	Consideration of whether certain design elements are dictated purely by utility.
Visual Comparison Test	Assessment of overall visual similarity between competing products.
Mosaicing of Prior Art	Examination of whether multiple prior designs can be combined to challenge novelty.
Interim Injunction	Temporary restraint order granted during pendency of the case.

Conclusion on Design Law and Ceiling Fans

The case highlights the continuing evolution of Indian design law and demonstrates how courts balance innovation, competition and consumer perception in industries shaped by functional limitations.

It also underscores the growing importance of intellectual property protection in consumer electrical products, where aesthetic appeal increasingly influences market success and brand identity.

Factual And Procedural Background

Orient Electric Limited, the plaintiff in the suit, is a company belonging to the CKA Birla Group, formerly known as the CK Birla Group, one of India’s most prominent business conglomerates with a presence across five continents and diverse sectors, including technology, automotive, home and building products and healthcare.

The group, with over 35,000 employees and 52 manufacturing facilities, has been associated with the Indian fan industry for over six decades. Orient Electric itself is a manufacturer and marketer of fans, lighting solutions, home appliances, switchgear and wires and claims to be the largest exporter of fans from India, with a distribution network spanning 125,000 retail outlets and a service network covering more than 450 cities.

The company markets its products in over 30 countries, and its predecessor had been using the trademark ‘Orient’ continuously since 1954.

Development Of AEON Fan Series

The genesis of the dispute lies in Orient Electric’s development of a new range of decorative ceiling fans called the ‘AEON’ fan series.

• The development process commenced in 2022.
• Industrial drawings and computer-aided design models were created by the research and development team.
• Multiple design iterations and prototype developments were undertaken.
• The entire exercise involved an expenditure of approximately two crore rupees.

Once the design was finalised, Orient Electric conducted a preliminary design search to confirm that the design satisfied the novelty requirements under the Designs Act, 2000, and thereafter applied for registration.

Design Registration Details

Particulars	Details
Registration Certificate Number	393299-001
Date of Registration	April 9, 2024
Class	23-04
Product	Ceiling Fan
Novelty Claim	Shape and configuration of the ceiling fan

The registration certificate itself recorded that the novelty of the design resided in the shape and configuration of the ceiling fan as illustrated and specifically not in any mechanical or functional aspects of the product.

Commercial Launch And Sales Performance

Following registration, Orient Electric commercially launched the AEON Fan Series in the Indian market in May 2024.

The company subsequently obtained an additional registration for a variant of the AEON series under Registration Certificate number 443637-001 dated January 9, 2025, which was commercially launched in April 2025.

Business Details	Figures
Cumulative Sales By March 20, 2026	Approximately 88.21 crore rupees
Advertising And Sales Promotion Expenditure	Rupees 13,123 Lakhs
Period	2025–2026 up to February 2026

Allegations Against Crompton Greaves

Orient Electric became aware that Crompton Greaves Consumer Electricals Limited, one of India’s leading consumer electrical companies with over a century of presence in the market, was in the process of introducing a new range of ceiling fans under the name ‘GRACE’ series.

Upon examining the design of the GRACE fans, Orient Electric concluded that the product reproduced the dominant visual features of its registered AEON design.

Features Allegedly Copied

• Tapered blade geometry
• Compact hub structure
• Seamless blade-hub transition
• Overall sculptural silhouette of the fan

Orient Electric alleged that this was a deliberate attempt by Crompton to take advantage of the goodwill and market reputation that had been built around the AEON series.

Court Proceedings Before Delhi High Court

Orient Electric filed a civil suit along with an application for an interim injunction under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908, before the High Court of Delhi.

First Hearing On March 30, 2026

The matter was first listed on March 30, 2026.

On that date, counsel appearing for Crompton Greaves made a statement before the court that the GRACE fans had already been launched on or about March 20, 2026, in retail outlets across at least four states in India.

States Mentioned
Maharashtra
Uttar Pradesh
Karnataka
Gujarat

This statement was also recorded in an affidavit filed by Crompton on March 31, 2026, along with geo-tagged photographs of retail outlets where the product was claimed to be displayed.

On the basis of this statement suggesting a pre-filing launch, counsel for Orient Electric did not press for an immediate ad-interim injunction and instead agreed to provide Crompton an opportunity to file a written reply to the injunction application.

Subsequent Disclosures And Controversy

However, in subsequent affidavits and invoices filed by the defendant, a very different picture emerged.

• The product had been transported from the manufacturing facility to the warehouse from March 7, 2026, onwards.
• The actual retail sale of the GRACE fans commenced only on April 6, 2026.
• The launch took place after the first date of hearing.

The Court took serious note of this discrepancy, observing that the plaintiff had approached the Court before the actual date of launch and that the initial representation made by Crompton’s counsel may have deprived the plaintiff of a timely ad-interim injunction order.

Arguments in the interim injunction application were heard on May 6, 2026, and the order was reserved.

Core Legal Dispute

The core dispute between the parties operated on two distinct but interconnected levels.

1. Whether Orient Electric’s registered design was valid and possessed the novelty and originality required under the Designs Act, 2000.
2. Whether Crompton’s GRACE fans infringed the registered AEON design.

Crompton’s Challenge To Validity

Crompton argued vigorously that the AEON design lacked novelty and originality.

Its case was that Orient Electric had simply picked up various design elements that had already appeared in prior published products and mosaicked them together, presenting the resulting combination as a novel design.

Prior Art References Relied Upon By Crompton

Prior Art / Product	Publication / Filing Date
Atomberg Renesa Enzel	Published since May 26, 2021
Atomberg Renesa+	Published since May 9, 2023
Crompton Air 360	Design Number 304236 filed April 2, 2018
LUKER J. LUKER USA Cosmos	Published since November 28, 2020
Luker Electric Technologies Design 381268-001	Filed March 11, 2023
Luker Electric Technologies Design 386386-001	Filed May 16, 2023
Luker Electric Technologies Design 371396-001	Filed September 24, 2022

Crompton compared specific individual elements of the AEON design with corresponding elements in these prior arts, element by element, to argue that nothing in the AEON design was truly novel.

Orient Electric’s Defense

Orient Electric countered that the design must be assessed as a whole and not broken down into individual elements.

• The visual combination of all the elements of the AEON design created a distinctive and protectable aesthetic identity.
• None of the prior arts relied upon by Crompton produced the same overall visual impression as the AEON fan.
• The practice of “mosaicing” prior art references was legally impermissible.

Key Legal Issues In The Case

Issues Related To Design Validity

• Whether the AEON fan design satisfied the novelty requirement under the Designs Act, 2000.
• Whether prior published designs destroyed the originality of the plaintiff’s registered design.
• Whether combining prior art references through mosaicing is permissible in design infringement disputes.

Issues Related To Design Infringement

• Whether Crompton’s GRACE fan reproduced the essential visual features of the AEON design.
• Whether the overall visual impression of the two products was substantially similar.
• Whether Orient Electric was entitled to interim injunctive relief.

Importance Of The Case

The dispute is significant in the field of Indian intellectual property law and industrial design protection because it raises important questions regarding the following:

• Protection of industrial and decorative product designs.
• The doctrine of novelty and originality under the Designs Act, 2000.
• The legal treatment of mosaicing in design law.
• Standards for interim injunctions in design infringement litigation.
• Assessment of overall visual impression in competing consumer products.

Reasoning And Analysis Of The Court

Justice Gedela’s reasoning is methodical, rooted in a careful application of established legal principles drawn from a body of authoritative precedent, and culminates in a nuanced finding that favours Orient Electric on multiple grounds.

Starting Point Of The Court’s Analysis

The starting point of the court’s analysis was the landmark judgement of a coordinate bench of the Delhi High Court in TTK Prestige Ltd versus KCM Appliances Pvt. Ltd, decided on April 13, 2023, in CS(COMM) 697/2022. The court described this judgement as a locus classicus, a leading authority on how design disputes are to be approached under the Designs Act, 2000.

The Court extracted at length the “takeaway” principles distilled in paragraph 38.13 of the TTK Prestige judgement, describing it as providing a comprehensive and authoritative framework for the resolution of design disputes.

Key Principles From TTK Prestige Judgment

• The sole purpose of the Designs Act is to protect novel and original designs for the benefit of those who have expended time, research and labour in conceiving them.
• While ocular appeal is the definitive test, courts must not apply their own subjective standards.
• Mosaicing of prior art designs is impermissible.
• Registration of a design is itself a facial acknowledgement of the existence of novelty and originality.
• In evaluating infringement, the comparison must be made through the lens of an instructed eye.

Principle Of Mosaicing In Design Law

The third, and perhaps most critical for this case, was the principle that mosaicing of prior art designs is impermissible. This means that novelty cannot be attacked by combining individual elements drawn from different prior design publications.

Any prior art cited as the basis for challenging the novelty of a registered design must be disclosed in a single prior document or in multiple documents where one expressly references the other.

Burden Of Proving Lack Of Novelty

The fourth principle was that registration of a design is itself a factual acknowledgement of the existence of novelty and originality, placing the burden of disproving novelty squarely on the party challenging the registration.

Test For Design Infringement

The fifth principle was that in evaluating infringement, the comparison must be made through the lens of an instructed eye, meaning the eye of a person who is aware of prior art and of the features that impart novelty to the registered design, and if the features that impart novelty are found replicated in the defendant’s product, infringement is established.

Court Analysis Of Crompton’s Prior Art Defense

Applying these principles, the court examined Crompton’s prior art challenge and found it legally untenable.

The court observed that Crompton had cited seven different prior arts, and its entire defence was built on comparing specific individual elements of the AEON design with corresponding individual elements from different prior art products.

This was precisely the kind of mosaicing that the TTK Prestige judgement had declared impermissible.

Court Findings On Prior Art

Issue	Court Finding
Use of multiple prior arts	Impermissible mosaicing under TTK Prestige principles
Overall visual impression	No prior art created the same overall visual appearance as AEON fan
Closest prior art	Atomberg Renesa Enzel lacked several AEON design features
Novelty challenge	Rejected by the Court

Analysis Of Atomberg Renesa Enzel Prior Art

The court then examined each of the cited prior arts and found that none of them, when viewed as a complete design applied to an article, produced the same overall visual impression as the AEON fan.

Specifically, the Court noted that even the closest prior art, the Atomberg Renesa Enzel, published since May 26, 2021, did not disclose the design of the bottom canopy, the shape of the bottom cover, or the shape of the bottom plate in the manner they appeared in the AEON design.

Reliance On Pidilite Industries’ judgement

The Court also drew support from the Bombay High Court’s judgement in Pidilite Industries Limited versus Astral Limited (formerly known as Resinova Chemie Limited) in Commercial IP Suit (L) No. 13638 of 2024, which had similarly held that it is not permissible to break down an article into its component parts and compare individual elements with parts of a competing design.

Selvel Industries’ Principle Explained

The Court further relied on the principle drawn from the Selvel Industries case, extracted in the Pidilite judgement, which had clarified that the phrase “combination of known designs” in Section 4(c) of the Designs Act, which prohibits registration of such combinations, refers to a combination of known articles and not to parts or elements of known articles.

This meant that even if individual components of a design had appeared in earlier products, their particular combination and arrangement in a novel way to produce a new overall visual impression was not prohibited and could constitute a registrable design.

Physical Examination Of The Rival Products

Having rejected Crompton’s novelty challenge, the Court proceeded to compare the two rival designs.

In an unusual and instructive step, Justice Gedela had actually requested the parties to physically bring their assembled fan products before the court for visual examination.

This in-person examination formed an important part of the court’s assessment.

Court Observations On Design Similarity

• The blade design of both fans employed a variable-width type design.
• The curve at the motor end of the blade matched the bottom cover radius in both products.
• The fluidic curve and line at the blade tip appeared to be a deliberate design choice replicated by Crompton.
• The longitudinal line and curve of the blade across its length matched in both products.
• The shape of the bottom cover in both fans had a curved and fluidic form.

Minor Differences Not Sufficient To Avoid Infringement

The court did acknowledge, fairly and with a degree of candour toward the defendant, that the bottom canopy and upper canopy of the GRACE fan appeared somewhat different from those of the AEON fan; specifically, Crompton’s canopies were more dome-shaped, while Orient Electric’s canopy was somewhat like half an hourglass.

However, the Court held that these were minor and peripheral differences in non-essential features and could not serve as a shield where the essential features of a design had been copied.

This reflected the principle from TTK Prestige that imitation does not imply identity and that copying of the novelty-imparting features is sufficient to constitute design piracy even if minor differences exist in other features.

Weakness In Crompton’s Defense

The court also noted the conspicuous omission in Crompton’s defence: the defendant had nowhere in its reply stated that its GRACE design was dissimilar to the plaintiff’s registered design.

The defence was entirely premised on attacking the validity of the registration, without actually engaging with the question of whether the two products looked similar.

This omission, the Court held, further strengthened the prima facie case for the plaintiff.

Injunction Despite Product Launch

On the question of granting an injunction despite the product having already been launched, the court acknowledged that ordinarily it would be reluctant to grant injunctive relief post-launch.

However, the Court found that the specific factual circumstances of this case made it just and appropriate to do so.

Timeline Of Events

Date	Event
March 20, 2026	Crompton claimed the product was launched across multiple states
March 30, 2026	The first court hearing took place
April 6, 2026	Actual retail sales commenced according to invoices and documents

Court Findings On Misrepresentation

The critical finding was that Crompton had initially represented on affidavit and through its counsel that the product had been launched on March 20, 2026, across multiple states.

It was only subsequently revealed, through invoices and other documents, that actual retail sales had commenced only on April 6, 2026, after the first court date of March 30, 2026.

The court found that Orient Electric had in fact approached the court before the actual date of retail launch and that it was the incorrect statement made by Crompton’s counsel which had led the plaintiff to not press for an immediate interim injunction on the first hearing.

The court held that the plaintiff could not be prejudiced by the incorrect representation made by the defendant regarding the date of launch and that this factor compelled the court to protect the plaintiff’s interests at this stage.

The Court also found that the photographs filed by Crompton as evidence of retail launch merely showed the product at retail premises but did not establish an actual date of sale.

Final Decision of the Court

Court granted the interim injunction application filed by Orient Electric. By its order dated May 14, 2026, the Court restrained Crompton Greaves, along with all its business associates, partners, directors, officers, family members, servants, agents, dealers, distributors and franchisees, from manufacturing, marketing, selling — including on online platforms — or using the registered design bearing number 393299-001 or any other design identical or deceptively similar to the plaintiff’s AEON Fan Series, including specifically the GRACE series of ceiling fans.

The Court further directed that there shall be no further sales of the infringing product from the date of the order, save for products already sold prior to the order. The defendant was additionally directed to maintain its complete records of sale and financial statements in respect of the infringing product from April 6, 2026, till the date of the order and to disclose these records by way of an affidavit filed in a sealed cover within four weeks.

The matter was listed for further hearing before the court on July 17, 2026. The Court expressly clarified that its observations and conclusions in this order were confined to the adjudication of the interim injunction application and were not to be treated as any expression on the final merits of the underlying suit.

Key Directions Issued by the Court

Issue	Court Direction
Interim Injunction	Crompton Greaves is restrained from manufacturing, marketing, selling or using the disputed design.
Infringing Products	Restrictions included GRACE series ceiling fans and similar products.
Online Sales	The ban extended to online platforms and digital marketplaces.
Existing Sales	Products already sold before the order were exempted.
Financial Records	The defendant was directed to maintain and disclose sales and financial statements.
Affidavit Filing	Records to be submitted in sealed cover within four weeks.
Next Hearing Date	July 17, 2026.

Points of Law Settled in the Case

This judgement makes several important contributions to the law of industrial design in India, reinforcing and extending the principles developed in earlier cases.

1. Absolute Prohibition on Mosaicing

The most significant point of law affirmed in this case is the absolute prohibition on mosaicing in design infringement and validity proceedings. The Court unequivocally confirmed that it is not permissible to challenge the novelty of a registered design by combining individual elements drawn from different prior art sources.

Each piece of prior art relied upon to challenge novelty must, when viewed as a whole, disclose a design that is identical or substantially similar to the registered design in all its essential features. Selecting one element from one prior art and another element from a different prior art and arguing that the combination renders the registered design non-novel are impermissible approaches.

2. Standard of Visual Comparison in Design Infringement Cases

The second important point concerns the standard of visual comparison in design infringement cases. The Court confirmed that the correct standard is the “instructed eye” test — the comparison must be made from the perspective of a person who is familiar with the prior art in the relevant field and is capable of discerning which features of the registered design are truly novel.

Purely subjective impressions are insufficient. At the same time, the Court confirmed that the test is ultimately visual and ocular — what matters is the overall visual impression created by the design as applied to the article and not a technical or functional analysis.

3. Minor Differences Do Not Defeat Design Infringement

The third important point is that minor differences in non-essential features do not defeat a claim of design infringement. If the essential novelty-imparting features of a registered design have been replicated in the defendant’s product, infringement is established even if the defendant has introduced minor variations in peripheral or secondary features.

4. Post-Launch Injunctions in Commercial Disputes

The fourth point concerns the circumstances in which post-launch injunctions may be granted. The court confirmed that while courts would ordinarily be reluctant to grant injunctive relief after a product has been commercially launched, this reluctance can be overcome where it is shown that the plaintiff had approached the court before the actual date of launch and was misled by incorrect representations by the defendant regarding the launch date.

5. Presumption of Novelty and Originality of Registered Designs

The fifth and final point, flowing from the application of the Designs Act, is that registration of a design by the Controller General of Designs carries a presumption of novelty and originality.

The burden of rebutting this presumption lies on the party challenging the registration, and that burden is a heavy one, requiring demonstration — through a single prior document disclosing the entire design — that the registered design lacks novelty.

Case Details

Particulars	Details
Case Title	Orient Electric Limited Vs Crompton Greaves Consumer Electricals Limited
Date of Order	May 14, 2026
Case Number	CS(COMM) 331/2026
Neutral Citation	2026:DHC:4264
Court	High Court of Delhi at New Delhi
Honourable Judge	Mr Justice Tushar Rao Gedela

Key Legal Takeaways

• Design novelty cannot be challenged through mosaicing of multiple prior arts.
• The “instructed eye” test remains the governing standard in design infringement matters.
• Minor cosmetic differences do not negate infringement if essential features are copied.
• Post-launch injunctions may still be granted in exceptional circumstances.
• Registered designs enjoy a strong presumption of novelty and originality under Indian law.

Disclaimer: Readers are advised not to treat this as a substitute for legal advice, as it may contain errors in perception, interpretation, and presentation.
 
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi