Delhi High Court Clarifies Threshold for Grant of Interim Injunction in Standard Essential Patent Disputes

The Division Bench of the Delhi High Court upheld an interim injunction in Canva Pty Ltd v. RxPrism Health Systems Pvt Ltd, affirming the Single Judge’s order restraining Canva from offering its “Present and Record” feature within India pending trial. The dispute concerned allegations of patent infringement relating to a system and method for content presentation and recording functionality.

The appellate court declined to interfere with the interim order, reiterating that appellate review of discretionary injunction orders must remain limited unless the decision is manifestly arbitrary or perverse. The Bench found that the plaintiff had established a prima facie case of infringement and that the balance of convenience favoured continuation of the restraint.

The ruling is significant for technology companies operating SaaS platforms in India. It demonstrates judicial willingness to grant and sustain interim injunctions even in complex software patent disputes where technical evidence is contested and the final determination on validity remains pending.

Legal Analysis

Patent rights in India are statutorily recognised under Section 48 of the Patents Act, 1970, which confers upon the patentee the exclusive right to prevent third parties from making, using, selling, or importing the patented invention. Interim injunctions are governed procedurally by Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908 and substantively by the well established triad of prima facie case, balance of convenience, and irreparable injury.

In Canva, the Court reaffirmed that once a credible prima facie case of infringement is demonstrated, commercial scale exploitation by the defendant may justify interim restraint, particularly where damages may not adequately compensate loss of market exclusivity. The Court also reiterated that challenges to patent validity at the interim stage must raise a credible and serious triable issue rather than a mere assertion of invalidity.

For technology companies, the decision underscores litigation exposure associated with feature level product rollouts. SaaS providers must conduct thorough freedom to operate assessments and document independent development pathways. The ruling signals that Indian courts remain receptive to strong interim patent enforcement, including against multinational technology entities.