Delhi High Court Rules Against Toyota in Patent Dispute with LMW

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Toyota, the Japanese technology giant, filed a patent infringement suit against Indian company LMW Limited, alleging unauthorized use of its patented fibre bundle concentrating apparatus (Indian Patent No. IN759), a component used in textile spinning machinery. Alongside the suit, Toyota sought interim relief by way of injunction to restrain LMW from continuing the alleged infringing activities.
However, the patent in question expired on 24 May 2025, during the pendency of the interim relief application.

Key Observations by Justice Saurabh Banerjee

1. Expiry Nullifies Interim Relief
The Court categorically held that no interim injunction can be granted in respect of a patent that no longer exists:
“Since the patent has expired… the Court is precluded from passing any effective or enforceable interim order. Any such order would be a nullity in law.”
2. No Need to Examine Merits
The Court refused to delve into the merits of the infringement claim, observing that:
“There is no reason to unnecessarily burden the records with observations which are not required, as it may affect the rights of either party in the future.”
3. Financial Disclosure Directed
While declining injunctive relief, the Court directed LMW to file an affidavit detailing sales and profits derived from the use of the patented apparatus before 24 May 2025. This disclosure is to be filed under sealed cover and may be inspected by Toyota at a later stage, with permission of the Court.

Legal Significance
A patent must be in force for the Court to consider any interim or final injunctive relief.
Expiration of a patent during litigation renders all injunctive claims infructuous.
Courts may still allow residual remedies such as accounting of profits, even post-expiry, to preserve the economic interests of a patent holder.
The decision reiterates the importance of timely enforcement of IP rights.

Final Outcome
The Court dismissed Toyota’s interim application under Order XXXIX Rules 1 & 2 of the CPC but kept the suit alive for other consequential reliefs, including monetary damages, based on LMW’s financial disclosures.

The matter is now listed before the Registrar for procedural directions on 20 July 2025.



Prepared by : Drashti S. Varmora (Advocate)