Bajaj Auto Ltd. v. TVS Motor Company Ltd.
Rule established
In patent infringement suits, the doctrine of equivalents applies in India. A product infringes if it performs substantially the same function in substantially the same way to achieve substantially the same result. Injunction granted against TVS Flame for infringing Bajaj's DTS-i technology patent.
Facts
- Bajaj Auto held Indian Patent No. 195904 for DTS-i twin spark technology
- TVS Motor launched "Flame 125" motorcycle using CC-VTi with twin spark plugs
- Bajaj claimed TVS infringed its patent by using two spark plugs for enhanced combustion
- TVS argued its technology was independently developed and structurally different
Issue
- Whether TVS's CC-VTi technology infringes Bajaj's DTS-i patent under the doctrine of equivalents.
Held
- Patent claims must be read with the specification (purposive construction)
- Doctrine of equivalents applicable: same function, same way, same result
- TVS Flame's twin spark system fell within the scope of Bajaj's patent claims
- Interim injunction granted against TVS
Ratio Decidendi
A patent is infringed not only by literal reproduction of claims but also by use of equivalents that perform substantially the same function in substantially the same way to achieve substantially the same result. Indian courts recognise the doctrine of equivalents.
How to use it in an exam
- Indian authority for doctrine of equivalents in patent law
- Shows practical enforcement of patent rights
- Key line: "In Bajaj Auto v. TVS Motor (2009), the Madras HC applied the doctrine of equivalents and held that TVS's twin spark technology infringed Bajaj's DTS-i patent as it performed the same function in the same way."
Source
Source: 2009 (40) PTC 589 (Mad)
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.