Recent Patent Case Law in India: Key Judicial Developments in 2024

Recent Patent Case Law in India: Key Judicial Developments in 2024–2025. Patent law in India has been witnessing dynamic growth, shaped by judicial pronouncements that balance innovation, public interest, and global standards. With rapid progress in pharmaceuticals, biotechnology, and digital technologies, courts are increasingly called upon to interpret provisions of the Patents Act, 1970 in line with international frameworks.
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The period between 2024 and 2025 has produced a series of landmark decisions, especially from the Delhi High Court and Madras High Court, that touch upon Standard Essential Patents (SEPs), Fair, Reasonable and Non-Discriminatory (FRAND) licensing, Section 3(i) exclusions, and interim injunctions in pharma disputes.
This article explores key cases Novo Nordisk v. Dr. Reddy’s, Philips v. Indian DVD makers, Xiaomi “Find Device”, Kemin (Section 3(i)), and Ericsson v. Lava and analyses their broader implications for India’s patent regime.
Novo Nordisk v. Dr. Reddy's & OneSource (Delhi High Court, May 2025)
Background
Novo Nordisk, a global leader in diabetes care, holds patents over semaglutide, an innovative drug used in the treatment of Type 2 diabetes. Indian companies Dr. Reddy’s Laboratories and OneSource sought to manufacture and market semaglutide. Novo Nordisk filed a suit for infringement before the Delhi High Court 
Court’s Findings

The Court granted an interim injunction under Section 108 of the Patents Act, 1970, restraining Dr. Reddy’s and OneSource from selling semaglutide in India.

However, the order allowed manufacturing for export to jurisdictions where Novo Nordisk did not hold valid patent rights.

The Court relied on Section 48, which confers exclusive rights to a patentee, and clarified that exports for non-patent jurisdictions would not constitute infringement in India.

Analysis
The ruling reflects the dual approach of Indian courts:

Protecting patent holders’ exclusive rights in the domestic market.

Allowing India to maintain its role as a global supplier of affordable generics through export flexibility.

This decision reinforces confidence in India’s judiciary for multinational pharma companies while ensuring that public health interests in non-patent jurisdictions are safeguarded.
Philips v. Indian DVD Makers (Delhi High Court, May 2025)
Background
Philips has long been an enforcer of its Standard Essential Patents (SEPs), particularly in the consumer electronics space. Several Indian DVD manufacturers allegedly used technologies covered by Philips’ SEPs without obtaining licenses.
Court’s Findings

The Court upheld Philips’ SEP rights, directing the Indian companies to obtain licenses on FRAND (Fair, Reasonable and Non-Discriminatory) terms.

The judgment stressed the importance of international licensing norms, aligning India with global SEP enforcement practices.

The Court noted that infringement of SEPs affects not just patentees but also the integrity of standardized technology markets.

Framework

Sections 104–114 of the Patents Act (enforcement of patent rights).

Doctrine of FRAND: Though not expressly codified in Indian law, courts have imported the concept to ensure fair licensing practices.

Analysis
This ruling is a milestone for SEP enforcement in India. It assures global technology companies that their essential patents will be respected. At the same time, it emphasizes fair licensing to prevent abuse of dominance under competition law principles. 
Xiaomi “Find Device” Case (Delhi High Court, March 2025)
Background
A dispute arose regarding Xiaomi’s “Find Device” feature, which allegedly infringed another company’s patent. The plaintiff sought an injunction to restrain Xiaomi from using the technology in its smartphones.
Court’s Findings

The Court refused to grant an interim injunction, holding that the case did not present a prima facie strong case of infringement.

The Court emphasized that injunctions should not be granted mechanically in high-tech industries where features are widely used.

Reference was made to Section 108, which gives courts discretion to grant injunctions and damages.

Analysis
This decision shows judicial caution in halting technological innovations. Courts are reluctant to grant injunctions where:

The balance of convenience tilts in favor of continued use.

Public interest in technological accessibility is high.

This approach reduces the risk of patent holdup in the digital ecosystem, ensuring competition while leaving the door open for damages if infringement is later proved.
Kemin Case – Section 3(i) of the Patents Act (Madras High Court, July 2025)
Background
Kemin sought patent protection for a method involving feeding poultry with ferulic acid esterase supplements. The Patent Office rejected the application citing Section 3(i), which excludes “any process for the medicinal, surgical, curative, prophylactic or other treatment of human beings or animals.”
Court’s Findings

The Madras High Court clarified that Section 3(i) does not cover inventions related to feed supplements or additives unless they claim methods of treatment per se.

The Court distinguished between therapeutic treatment and nutritional enhancement, observing that only the former falls within the exclusion.

Accordingly, such claims may be patentable if drafted carefully to cover compositions and additives rather than treatment methods.

Analysis
This ruling offers interpretative clarity on one of the most debated exclusions under Indian patent law. For agri-biotech companies and poultry feed innovators, it provides a roadmap for structuring patent claims.
It also underscores the judiciary’s role in balancing statutory exclusions with the need to promote innovation in agriculture and animal health.
Ericsson v. Lava (Delhi High Court, 2024)
Background
Ericsson, a telecom giant, holds SEPs for mobile communication standards. Lava, an Indian handset manufacturer, was accused of infringing Ericsson’s SEPs without paying fair royalties.
Court’s Findings

The Delhi High Court determined a FRAND royalty rate of 1.05% of the net selling price of Lava’s devices.

The Court carefully analyzed global royalty benchmarks, emphasizing fairness to both patentees and licensees.

The judgment highlighted the balance between SEP enforcement and accessibility of affordable devices in India.

Analysis
This is one of India’s first detailed FRAND royalty determinations, setting a precedent for future SEP disputes. By quantifying royalty obligations, the Court has provided certainty for both multinational SEP holders and Indian manufacturers.
Broader Legal Themes Emerging
Pharma Patents and Public Health
Cases like Novo Nordisk highlight the delicate balance between rewarding innovation and maintaining India’s global role in generic exports.
Standard Essential Patents and FRAND Enforcement
The Philips and Ericsson rulings show that India is increasingly aligned with global standards. Indian courts are willing to enforce SEP rights but also insist on fair licensing terms.
Judicial Restraint in Injunctions
The Xiaomi case demonstrates caution in granting injunctions where consumer access and competition may be harmed, reflecting a nuanced approach to patent enforcement.
Clarity on Section 3(i) Exclusions
The Kemin judgment is crucial for biotech and agri-tech innovators. It reaffirms that statutory exclusions under Section 3(i) must be interpreted narrowly, leaving room for patentability in nutrition and feed innovation.
Conclusion
The past two years have seen Indian courts strengthening patent jurisprudence while maintaining a balance with public interest and competition. For innovators, these rulings provide greater certainty in protecting intellectual property. For Indian companies, they highlight the need to respect SEP licensing frameworks and carefully draft patent applications in excluded fields. For policymakers, the cases underline India’s gradual integration with global IP practices, without compromising its role as a supplier of affordable medicines and technologies. As India continues to attract global investment in pharmaceuticals, biotech, and digital technologies, these judgments mark a decisive step towards a mature and internationally harmonized patent regime. 
FAQ's 
Q1. What was the main issue in Novo Nordisk v. Dr. Reddy’s case?
Ans. The case concerned infringement of Novo Nordisk’s patent on the diabetes drug semaglutide. The Delhi High Court restrained Indian companies from selling it in India but permitted manufacturing for export where no patent applied.
Q2. Why is the Philips v. Indian DVD makers case important?
Ans. It reinforced enforcement of Standard Essential Patents (SEPs) in India and required Indian DVD makers to seek licenses on FRAND terms, aligning India with global IP enforcement practices. 
Q3. What did the Delhi High Court decide in the Xiaomi “Find Device” case?
 Ans. The Court refused to grant an injunction, noting that interim relief should not be granted without a strong prima facie case. This showed judicial caution in halting consumer technologies. 
Q4. What does Section 3(i) of the Patents Act, 1970 state?
Ans. Section 3(i) excludes from patentability any process for the medicinal, surgical, curative, prophylactic or other treatment of humans or animals. 
Q5. How did the Kemin case clarify Section 3(i)?
Ans. The Madras High Court ruled that feed supplements and additives do not automatically fall under Section 3(i). Only therapeutic treatment methods are excluded, leaving room for innovation in nutrition and agri-biotech patents. 
Q6. What was the outcome of Ericsson v. Lava?
 Ans. The Delhi High Court fixed a FRAND royalty rate of 1.05% of the net selling price of Lava’s devices, making it a benchmark for future SEP licensing disputes in India. 
Q7. What are FRAND terms in patent law?
Ans. FRAND stands for Fair, Reasonable and Non-Discriminatory licensing obligations. It ensures SEP owners license their patents fairly, without abusing dominance, while allowing implementers access to essential technologies. 
Q8. Why do Indian courts sometimes refuse injunctions in patent disputes?
Ans. Courts may refuse injunctions when public interest, competition, or access to essential technologies could be harmed. Instead, they may award damages later if infringement is proved. 
Q9. How do SEP disputes affect Indian businesses?
Ans. Indian manufacturers must obtain SEP licenses from global technology companies to avoid infringement. Court rulings like Philips and Ericsson ensure that licensing is transparent and based on FRAND principles. 
Q10. What lessons can pharma companies learn from Novo Nordisk’s case?
Ans. Pharma innovators should expect stronger patent enforcement in India. At the same time, they should be aware that courts may allow exports to non-patent jurisdictions to balance public health interests. 
Q11. How do these cases impact India’s innovation ecosystem?
Ans. They provide clarity and confidence to patentees while ensuring affordable access for consumers. This balance encourages both foreign investment and domestic R&D. 
Q12. Are Indian patent rulings aligned with global trends?
 Ans. Yes. Cases like Philips and Ericsson show India’s commitment to SEP and FRAND principles, similar to practices in the EU and US, while the Kemin case reflects India’s nuanced approach to statutory exclusions.

Patent law in India has been witnessing dynamic growth, shaped by judicial pronouncements that balance innovation, public interest, and global standards. With rapid progress in pharmaceuticals, biotechnology, and digital technologies, courts are increasingly called upon to interpret provisions of the Patents Act, 1970 in line with international frameworks.

Leran more about Patent Registration.

The period between 2024 and 2025 has produced a series of landmark decisions, especially from the Delhi High Court and Madras High Court, that touch upon Standard Essential Patents (SEPs), Fair, Reasonable and Non-Discriminatory (FRAND) licensing, Section 3(i) exclusions, and interim injunctions in pharma disputes.

This article explores key cases Novo Nordisk v. Dr. Reddy’s, Philips v. Indian DVD makers, Xiaomi “Find Device”, Kemin (Section 3(i)), and Ericsson v. Lava and analyses their broader implications for India’s patent regime.

Novo Nordisk v. Dr. Reddy's & OneSource (Delhi High Court, May 2025)

Background

Novo Nordisk, a global leader in diabetes care, holds patents over semaglutide, an innovative drug used in the treatment of Type 2 diabetes. Indian companies Dr. Reddy’s Laboratories and OneSource sought to manufacture and market semaglutide. Novo Nordisk filed a suit for infringement before the Delhi High Court

Court’s Findings

The Court granted an interim injunction under Section 108 of the Patents Act, 1970, restraining Dr. Reddy’s and OneSource from selling semaglutide in India.
However, the order allowed manufacturing for export to jurisdictions where Novo Nordisk did not hold valid patent rights.
The Court relied on Section 48, which confers exclusive rights to a patentee, and clarified that exports for non-patent jurisdictions would not constitute infringement in India.

Analysis

The ruling reflects the dual approach of Indian courts:

Protecting patent holders’ exclusive rights in the domestic market.
Allowing India to maintain its role as a global supplier of affordable generics through export flexibility.

This decision reinforces confidence in India’s judiciary for multinational pharma companies while ensuring that public health interests in non-patent jurisdictions are safeguarded.

Philips v. Indian DVD Makers (Delhi High Court, May 2025)

Background

Philips has long been an enforcer of its Standard Essential Patents (SEPs), particularly in the consumer electronics space. Several Indian DVD manufacturers allegedly used technologies covered by Philips’ SEPs without obtaining licenses.

Court’s Findings

The Court upheld Philips’ SEP rights, directing the Indian companies to obtain licenses on FRAND (Fair, Reasonable and Non-Discriminatory) terms.
The judgment stressed the importance of international licensing norms, aligning India with global SEP enforcement practices.
The Court noted that infringement of SEPs affects not just patentees but also the integrity of standardized technology markets.

Framework

Sections 104–114 of the Patents Act (enforcement of patent rights).
Doctrine of FRAND: Though not expressly codified in Indian law, courts have imported the concept to ensure fair licensing practices.

Analysis

This ruling is a milestone for SEP enforcement in India. It assures global technology companies that their essential patents will be respected. At the same time, it emphasizes fair licensing to prevent abuse of dominance under competition law principles.

Xiaomi “Find Device” Case (Delhi High Court, March 2025)

Background

A dispute arose regarding Xiaomi’s “Find Device” feature, which allegedly infringed another company’s patent. The plaintiff sought an injunction to restrain Xiaomi from using the technology in its smartphones.

Court’s Findings

The Court refused to grant an interim injunction, holding that the case did not present a prima facie strong case of infringement.
The Court emphasized that injunctions should not be granted mechanically in high-tech industries where features are widely used.
Reference was made to Section 108, which gives courts discretion to grant injunctions and damages.

Analysis

This decision shows judicial caution in halting technological innovations. Courts are reluctant to grant injunctions where:

The balance of convenience tilts in favor of continued use.
Public interest in technological accessibility is high.

This approach reduces the risk of patent holdup in the digital ecosystem, ensuring competition while leaving the door open for damages if infringement is later proved.

Kemin Case – Section 3(i) of the Patents Act (Madras High Court, July 2025)

Background

Kemin sought patent protection for a method involving feeding poultry with ferulic acid esterase supplements. The Patent Office rejected the application citing Section 3(i), which excludes “any process for the medicinal, surgical, curative, prophylactic or other treatment of human beings or animals.”

Court’s Findings

The Madras High Court clarified that Section 3(i) does not cover inventions related to feed supplements or additives unless they claim methods of treatment per se.
The Court distinguished between therapeutic treatment and nutritional enhancement, observing that only the former falls within the exclusion.
Accordingly, such claims may be patentable if drafted carefully to cover compositions and additives rather than treatment methods.

Analysis

This ruling offers interpretative clarity on one of the most debated exclusions under Indian patent law. For agri-biotech companies and poultry feed innovators, it provides a roadmap for structuring patent claims.

It also underscores the judiciary’s role in balancing statutory exclusions with the need to promote innovation in agriculture and animal health.

Ericsson v. Lava (Delhi High Court, 2024)

Background

Ericsson, a telecom giant, holds SEPs for mobile communication standards. Lava, an Indian handset manufacturer, was accused of infringing Ericsson’s SEPs without paying fair royalties.

Court’s Findings

The Delhi High Court determined a FRAND royalty rate of 1.05% of the net selling price of Lava’s devices.
The Court carefully analyzed global royalty benchmarks, emphasizing fairness to both patentees and licensees.
The judgment highlighted the balance between SEP enforcement and accessibility of affordable devices in India.

Analysis

This is one of India’s first detailed FRAND royalty determinations, setting a precedent for future SEP disputes. By quantifying royalty obligations, the Court has provided certainty for both multinational SEP holders and Indian manufacturers.

Broader Legal Themes Emerging

Pharma Patents and Public Health

Cases like Novo Nordisk highlight the delicate balance between rewarding innovation and maintaining India’s global role in generic exports.

Standard Essential Patents and FRAND Enforcement

The Philips and Ericsson rulings show that India is increasingly aligned with global standards. Indian courts are willing to enforce SEP rights but also insist on fair licensing terms.

Judicial Restraint in Injunctions

The Xiaomi case demonstrates caution in granting injunctions where consumer access and competition may be harmed, reflecting a nuanced approach to patent enforcement.

Clarity on Section 3(i) Exclusions

The Kemin judgment is crucial for biotech and agri-tech innovators. It reaffirms that statutory exclusions under Section 3(i) must be interpreted narrowly, leaving room for patentability in nutrition and feed innovation.

Conclusion

The past two years have seen Indian courts strengthening patent jurisprudence while maintaining a balance with public interest and competition. For innovators, these rulings provide greater certainty in protecting intellectual property. For Indian companies, they highlight the need to respect SEP licensing frameworks and carefully draft patent applications in excluded fields. For policymakers, the cases underline India’s gradual integration with global IP practices, without compromising its role as a supplier of affordable medicines and technologies. As India continues to attract global investment in pharmaceuticals, biotech, and digital technologies, these judgments mark a decisive step towards a mature and internationally harmonized patent regime.

FAQ's

Q1. What was the main issue in Novo Nordisk v. Dr. Reddy’s case?

Ans. The case concerned infringement of Novo Nordisk’s patent on the diabetes drug semaglutide. The Delhi High Court restrained Indian companies from selling it in India but permitted manufacturing for export where no patent applied.

Q2. Why is the Philips v. Indian DVD makers case important?

Ans. It reinforced enforcement of Standard Essential Patents (SEPs) in India and required Indian DVD makers to seek licenses on FRAND terms, aligning India with global IP enforcement practices.

Q3. What did the Delhi High Court decide in the Xiaomi “Find Device” case?

Ans. The Court refused to grant an injunction, noting that interim relief should not be granted without a strong prima facie case. This showed judicial caution in halting consumer technologies.

Q4. What does Section 3(i) of the Patents Act, 1970 state?

Ans. Section 3(i) excludes from patentability any process for the medicinal, surgical, curative, prophylactic or other treatment of humans or animals.

Q5. How did the Kemin case clarify Section 3(i)?

Ans. The Madras High Court ruled that feed supplements and additives do not automatically fall under Section 3(i). Only therapeutic treatment methods are excluded, leaving room for innovation in nutrition and agri-biotech patents.

Q6. What was the outcome of Ericsson v. Lava?

Ans. The Delhi High Court fixed a FRAND royalty rate of 1.05% of the net selling price of Lava’s devices, making it a benchmark for future SEP licensing disputes in India.

Q7. What are FRAND terms in patent law?

Ans. FRAND stands for Fair, Reasonable and Non-Discriminatory licensing obligations. It ensures SEP owners license their patents fairly, without abusing dominance, while allowing implementers access to essential technologies.

Q8. Why do Indian courts sometimes refuse injunctions in patent disputes?

Ans. Courts may refuse injunctions when public interest, competition, or access to essential technologies could be harmed. Instead, they may award damages later if infringement is proved.

Q9. How do SEP disputes affect Indian businesses?

Ans. Indian manufacturers must obtain SEP licenses from global technology companies to avoid infringement. Court rulings like Philips and Ericsson ensure that licensing is transparent and based on FRAND principles.

Q10. What lessons can pharma companies learn from Novo Nordisk’s case?

Ans. Pharma innovators should expect stronger patent enforcement in India. At the same time, they should be aware that courts may allow exports to non-patent jurisdictions to balance public health interests.

Q11. How do these cases impact India’s innovation ecosystem?

Ans. They provide clarity and confidence to patentees while ensuring affordable access for consumers. This balance encourages both foreign investment and domestic R&D.

Q12. Are Indian patent rulings aligned with global trends?

Ans. Yes. Cases like Philips and Ericsson show India’s commitment to SEP and FRAND principles, similar to practices in the EU and US, while the Kemin case reflects India’s nuanced approach to statutory exclusions.