The Delhi High Court’s decision in Nippon Steel Corporation vs The Controller of Patents [C.A.(COMM.IPD-PAT) 488/2022; decision dated April 17, 2026] reinforces that a refusal or acceptance order in a patent proceeding must disclose intelligible reasons and demonstrate genuine engagement with the applicant’s case.

The Appellant challenged the refusal of its patent application number 10182/DELNP/2012, refused on the ground of lack of inventive step. It was contended that the Controller had reproduced extracts from prior-art documents without analysing the applicant’s submissions and explaining why the claimed invention would have been obvious to a person skilled in the art (PSITA).

The Court found that the section of the impugned order titled “Scientific and Technical Analysis” was nothing more than verbatim reproduction of the disclosure in cited prior art references. The analytical bridge between those disclosures and the conclusion of obviousness was absent. The order did not adequately identify how the prior art, whether individually or in combination, taught the essential features of the claims, nor did it address the applicant’s technical distinctions and post-hearing submissions.

The Court also reiterated the principles governing assessment of inventive step laid down in Agriboard International LLC vs. Deputy Controller, observing that the Controller must discuss the invention disclosed in the prior art documents as well as the claimed invention and discuss the manner in which the claimed invention would be obvious to a PSITA.

The Court remarked that being a quasi-judicial authority, is it the duty of the Controller to provide reasons for either acceptance or refusal of a patent application.

In view of the foregoing, the Court set aside the impugned order and remanded the matter to the Patent Office for fresh consideration.