Delhi High Court Upholds Design Piracy Injunction Against Aqualite Industries

Aqualite's Appeal Dismissed in Design Piracy Case Involving Relaxo Footwears' Registered Designs

In a landmark judgment delivered on November 18, 2025, the Delhi High Court, comprising Justices C. Hari Shankar and Om Prakash Shukla, upheld the interlocutory injunction against Aqualite Industries Private Ltd., restraining it from manufacturing and selling footwear that replicates the registered designs of Relaxo Footwears Limited. The court dismissed the appeal filed by Aqualite, affirming the interim injunction granted by the learned Single Judge in favor of Relaxo.

The dispute centered around Relaxo's registered designs for its BHG 136 and BHG 137 models of Hawai slippers, which feature unique side ridges certified for their novelty under the Designs Act, 2000. Aqualite's argument that these designs were not novel and were subject to prior publication was rejected. The court examined the alleged prior arts cited by Aqualite, including footwear designs already in the market, and concluded that the suit designs possessed distinct visual appeal and novelty.

Aqualite had sought to challenge the validity of the registered designs on grounds of prior publication and lack of originality under Section 19 of the Designs Act. However, the court found that the cited prior arts did not demonstrate substantial similarity or novelty dilution. The instructed eye test was applied to determine the distinctiveness of the side ridges in Relaxo's designs compared to the prior arts presented.

The court emphasized that design piracy under Section 22 of the Designs Act occurs when novel features certified in a design registration are replicated without consent. It was determined that Aqualite's products featured identical side ridges, thereby constituting piracy of Relaxo's registered designs.

In its judgment, the court addressed the scope of registration under Section 2(d) of the Designs Act, highlighting that a design consists of specific features applied to an article, rather than the article itself. The judgment reinforced the principle that novelty and originality are to be assessed from the perspective of an instructed eye, familiar with prior art and trade variants.

The dismissal of Aqualite's appeal reinforces the protection afforded to registered designs and serves as a significant precedent in design piracy litigation. The court's decision underscores the importance of maintaining the integrity of registered designs and deterring unauthorized replication in the footwear industry.

Bottom Line:

Designs Act, 2000 - Scope of piracy under Section 22 - Replication of novel features certified in a design registration, such as shape, configuration, and surface pattern, constitutes piracy - Prior art and prior publication do not invalidate a design unless substantial similarity exists between the registered design and prior designs.

Statutory provision(s): Designs Act, 2000 Section 22(1), Section 19(1)(b), Section 19(1)(c), Section 2(d), Section 4

Aqualite Industries Private Ltd. v. Relaxo Footwears Limited, (Delhi)(DB) : Law Finder Doc Id # 2810218