Commercial Court's Rejection of Interim Injunction Reversed; Case Involving Design Cancellation to be Heard by High Court
In a significant ruling on June 16, 2026, the Gujarat High Court has mandated the transfer of a civil suit from the Commercial Court to the High Court, highlighting procedural missteps in handling a design infringement case. The judgment was delivered by a division bench comprising Chief Justice Mrs. Sunita Agarwal and Justice D.N. Ray, in the matter of M/s Satyam Fashion versus Meesho Technologies Private Limited.
The case centered around a dispute over the infringement of a registered design held by M/s Satyam Fashion. The appellant, M/s Satyam Fashion, had sought a temporary injunction against Meesho Technologies, alleging unauthorized use of its registered design. However, the Commercial Court at Surat had earlier rejected the application for interim relief. The court cited grounds that the registered design lacked novelty and originality, with the defendant pointing to pre-existing similar designs publicly available, including those on the Meesho platform prior to the plaintiff's registration.
The crux of the High Court's decision lay in the application of Section 22(4) of the Designs Act, 2000. The section mandates that when a defendant in a design infringement suit seeks cancellation of the registered design as a defense, the case must be transferred to the High Court. The Gujarat High Court found that the Commercial Court erred by not transferring the suit upon such a defense being raised.
The bench referenced the Supreme Court's decision in S.D. Containers Indore v. Mold-Tek Packaging Ltd., which affirmed the necessity of transferring suits involving design cancellation defenses to the High Court, even within the framework of the Commercial Courts Act, 2015. The Gujarat High Court underscored that the Commercial Court's procedural oversight in continuing to adjudicate the interim injunction application was inconsistent with statutory requirements.
In its order, the High Court reversed the Commercial Court's decision and directed the immediate transfer of the suit to the High Court for further proceedings. The court emphasized that the transfer should occur within one week from the receipt of the order, ensuring compliance with legal protocols.
This ruling underscores the judiciary's commitment to upholding statutory provisions in design infringement cases, ensuring that cases are adjudicated by the competent legal authority, and rectifying procedural oversights by lower courts. The appeal by M/s Satyam Fashion has been allowed, with no orders on costs.
The connected civil application for stay, tied to the appeal, was also disposed of in light of the primary ruling.
Bottom line:-
Section 22(4) of the Designs Act, 2000 mandates the transfer of a suit to the High Court when the defendant seeks cancellation of the registered design as a ground of defense.
Statutory provision(s):
Designs Act, 2000 Sections 19, 22(4); Civil Procedure Code, 1908 Order XXXIX Rules 1 and 2; Commercial Courts Act, 2015
