The Madras High Court, in the case of Maya Appliances Pvt. Ltd. vs Deputy Controller of Patents and Designs & Anr.[CMA(PT) No.5 of 2025], set aside an order of the Deputy Controller of Patents and Designs that revoked patent no. 452008, granted in favour of Maya Appliances Pvt. Ltd., entitled “An Intelligent Cooking Stove System”. The revocation was ordered pursuant to a post-grant opposition filed by Versuni India Home Solutions Ltd. under Section 25(2) of the Patents Act, 1970.

Versuni had opposed the grant of the subject patent on several grounds, including lack of novelty, lack of inventive step, insufficiency of disclosure, non-patentability under Section 3(f). Of these, the Controller only accepted the ground of lack of inventive step and revoked the patent on that basis.

Notably, two of the prior art documents relied upon by Versuni (D2 and D3) were in Chinese language and the Controller had explicitly recorded in the impugned order that the machine-translated versions of said documents were being excluded from the record under Rule 61(2) of the Patents Rules, 2003, which mandates that where a document in a language other than English is referred to in any notice, statement, or evidence, an attested English translation must be furnished in duplicate. However, despite this exclusion, the Controller explicitly relied on the drawings in D2 while arriving at the conclusion that the claimed invention lacked inventive step.

The Appellant challenged the revocation, contending that such reliance on excluded documents was impermissible and indicative of procedural lapse.

In response, it was contended that the conclusion on lack of inventive step was not based solely on D2, but rather on the combined teachings of prior art documents D1, D2, and D5. It was further argued that the absence of acceptable translation of D2 was immaterial, as the technical drawing relied upon was sufficient to demonstrate that D2 disclosed features relevant to the subject patent.

The Court concurred with the Appellant, holding that the reliance on D2’s drawing rendered the decision untenable. The Court alluded that once documents are excluded under Rule 61(2), the Controller ought not to rely onany part of them, including visual content such as drawings.

The Court also found that the Controller had combined features from documents D1, D2 and D5 without providing any reasoning or analysis to explain why a person skilled in the art would be motivated to combine these references. Additionally, The Court observed that the impugned order lacked cogent reasoning for rejecting the other grounds raised in the opposition. In view of the absence of a reasoned assessment on both the accepted and rejected grounds, the Court held that the order was unsustainable.

In view of the foregoing, the Court set aside the revocation order and remanded the matter for fresh consideration.