By Jigyasa Pareek

The Division Bench of the Karnataka High Court, in Priya Industries & Anr. vs Vishwanatha K. [COMAP No. 351/2026; decision dated July 22, 2026], set aside the ex parte ad interim injunction order, passed by the Commercial Court, restraining the Appellants from manufacturing or selling products alleged to infringe patent number IN259204. The Court held that an order granting interim relief on the basis of a prima facie case of patent infringement must clearly disclose the reasoning supporting such a finding.

The High Court found that the impugned order neither indicated that the suit patent claims had been considered nor identified which features of the Appellants’ machine allegedly infringed the patent claims.

The Respondent sought to sustain the injunction by relying, inter alia, on an expert report from NIT Karnataka and other material which, according to them, demonstrated infringement. The High Court, however, observed that even if such material had been placed before the Commercial Court, the order did not indicate that the expert report had been analysed or considered.

The Court accordingly held that the impugned order was not sustainable as it did not clearly set out the reasons for arriving at a prima facie view that the patent had been infringed. The decision underscores that where an injunction is granted, the order must demonstrate the Court’s application of mind to the patent claims and the allegedly infringing product and disclose the basis on which infringement is prima facie established.