Case Summary: Aquestia Limited v. Automat Industries Private Limited
The case of Aquestia Limited v. Automat Industries Private Limited represents a significant judicial examination of patent infringement within the realm of fluid control valve technology. This legal dispute centers on allegations that the defendants’ product, marketed under the “Hydromat” brand, infringes the plaintiff’s registered patent, IN 427050, titled “A Fluid Control Valve.” The case raises critical questions about patent claim construction, the relevance of a defendant’s own patent as a defense to infringement, and the role of prior employment relationships in intellectual property disputes.
Factual Background
Aquestia Limited, the plaintiff, is a company with a robust portfolio of approximately 145 patents, specializing in the development of advanced valve technologies, including mechanical and hydraulic valves. The suit patent, IN 427050, pertains to a fluid control valve characterized by an asymmetric sealing diaphragm, which enhances low-pressure operation and fluid flow control. Originally granted to Dorot Management Control Valves Ltd., the patent was later assigned to Aquestia following a merger.
The plaintiff has achieved significant commercial success, with global revenues exceeding USD 100 million in 2023 and sales of approximately 28,000 units of the patented valves, generating around USD 5 million. These products are distributed globally, including in India, through established trade channels.
The defendants, led by Automat Industries Private Limited, manufacture and sell irrigation solutions, including valves branded as “Hydromat.” Defendant no. 5, a former employee of Netafim (the plaintiff’s distributor), joined Automat Industries as Chief Technology Officer in March 2020. The plaintiff alleges that during his tenure at Netafim (2013–2019), he was privy to technical details of the suit patent, especially the “Series 75 Valve” technology.
In January 2023, suspicions were raised upon learning of his role in the Hydromat valves, which were being promoted for their “Cured Bridge” innovation. Subsequent investigations in October 2023 and February 2024 confirmed the plaintiff’s belief that these valves infringed the suit patent. Detailed examinations were conducted, leading to the initiation of legal proceedings in October 2024.
The defendants argue that their Hydromat valves are covered by their own patent, IN 536, featuring a curved sealing bridge. They deny any infringement and assert that Defendant no. 5 only worked on commercial matters at Netafim. Additionally, they claim the suit is motivated by mala fide intent and is barred by delay and laches.
Procedural Background
The plaintiff filed suit CS (COMM) 860/2024 seeking a permanent injunction against infringement of patent IN 427050. Alongside, an application (I.A. 4111/2024) under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908, was filed for an interim injunction. The plaintiff also initiated a revocation petition (CO (COMM.IPD-PAT) 1/2025) challenging the defendants’ patent IN 536. The defendants responded with written statements denying infringement.
Core Dispute
The central issue is whether the Hydromat valves infringe Claim 1 of the suit patent, which describes a fluid control valve with an asymmetric sealing diaphragm and differential diaphragm surface areas. The plaintiff cites measurements (4900 mm² inlet vs. 4488 mm² outlet) to support their claim. The defendants argue their valve design differs technically and is covered by IN 536. They also raise defenses of delay, lack of commercial presence in India by the plaintiff, and misuse of confidential information by defendant no. 5.
Discussion on Judgments
For the Plaintiff:
- Hindustan Lever Limited v. Lalit Wadhwa (2007 SCC OnLine Del 1077) – clarified that a patent grant does not immunize infringement of an earlier patent.
- Biswanath Prasad Radhey Shyam v. Hindustan Metal Industries ((1979) 2 SCC 511) – emphasized that infringement must be assessed based on the patent claims.
- 2025 judgments (SCC OnLine Del 4681 and 4883) and Guala Closures were cited to support claim-based infringement analysis.
For the Defendants:
- Boehringer (2021 SCC OnLine Del 5383) – cited for public interest concerns. The court held this inapplicable due to the nature of the products involved (not public health).
- 2024 SCC OnLine Del 5510 – repeatedly cited by defendants to support their arguments on non-infringement.
Reasoning and Analysis of the Judge
The judge adopted a claim-to-product comparison approach. Measurements presented by the plaintiff demonstrated the asymmetric diaphragm, supporting the infringement claim. The defendants failed to provide counter-evidence. Citing Hindustan Lever, the court ruled that even with their own patent, the defendants could still infringe an earlier patent.
The shape of the sealing bridge was deemed irrelevant since the suit patent’s Claim 1 did not limit the shape and Claim 9 included a curved bridge, covering the defendants’ design. The involvement of defendant no. 5 was substantiated through confidential emails and his technical role in both companies, raising concerns of misuse of proprietary know-how.
Delay was justified by the plaintiff through a timeline of investigation and testing. Sales data rebutted the claim of no commercial presence in India. The court found a prima facie case of infringement and ruled in favor of granting an interim injunction.
Final Decision
The court granted the plaintiff’s application for an interim injunction, restraining the defendants and their associates from manufacturing, selling, distributing, advertising, exporting, or importing any product infringing patent IN 427050. All online listings and promotions of Hydromat valves were ordered to be taken down. The court clarified these findings are interim and not determinative of the final outcome.
Law Settled in This Case
- A patent granted to a defendant does not provide a defense against infringement of a prior patent.
- Claim-to-product analysis is the proper approach in infringement matters.
- The specific shape of a claimed component is irrelevant if the patent covers multiple embodiments.
- Prior employment relationships and documented access to technical information can support claims of misuse of proprietary knowledge.
Case Details
Case Title: Aquestia Limited Vs. Automat Industries Private Limited
Date of Order: 01.08.2025
Case Number: CS (COMM) 860/2024
Neutral Citation: 2025:DHC:6312
Court: High Court of Delhi
Judge: Hon’ble Mr. Justice Amit Bansal
Disclaimer: The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By: Advocate Ajay Amitabh Suman, IP Adjutor – Patent and Trademark Attorney
Email: [email protected], Ph no: 9990389539
