Case Summary: Lalita Goyal v. Sumit Garg
The case of Lalita Goyal v. Sumit Garg, adjudicated by the High Court of Delhi, represents a significant judicial intervention in the realm of design law under the Designs Act, 2000. This appeal, lodged under FAO (COMM) 125/2025, challenges the decision of the District Judge (Commercial Court), North District, Delhi, which granted an interim injunction in favor of the respondent, Sumit Garg, restraining the appellant, Lalita Goyal, from using a design registered in Garg’s favor.
The core issue revolves around the procedural mandate of Section 22(4) of the Designs Act, which requires the transfer of a suit to the High Court when the validity of a design registration is challenged. The High Court’s ruling clarifies the mandatory nature of this provision, highlighting its non-discretionary application and underscoring the importance of jurisdictional propriety in intellectual property disputes.
This case study provides a detailed analysis of the factual and procedural context, the legal issues at stake, the judicial reasoning, and the principles established, offering insights into the enforcement of design rights in India.
Factual Background
Lalita Goyal holds a registered design under the Designs Act, 2000, which forms the basis of his claim against Goyal. Garg initiated a suit (CS (Comm) 6742/2024) before the Commercial Court, alleging that Goyal was infringing his registered design by using it without authorization.
To protect his rights pending the suit’s resolution, Garg filed an application under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908, seeking an interim injunction. In her defense, Goyal challenged the validity of Garg’s design registration, likely on grounds such as lack of novelty or prior publication. Goyal further argued that this challenge necessitated the transfer of the suit to the High Court under Section 22(4) of the Designs Act.
Procedural Background
The dispute originated in the Commercial Court, North District, Delhi, where Sumit Garg filed CS (Comm) 6742/2024 seeking a permanent injunction and moved an interim application. Goyal, in her written statement, challenged the validity of the design, invoking grounds under Section 19 of the Designs Act and requested transfer under Section 22(4).
The Commercial Court dismissed her request as vague and granted the interim injunction on 16 April 2025. Goyal filed an appeal (FAO (COMM) 125/2025) before the High Court, which was heard by a Division Bench comprising Justice C. Hari Shankar and Justice Om Prakash Shukla.
Core Dispute
The primary issue was whether the Commercial Court erred in not transferring the suit despite Goyal’s challenge to the design’s validity. Goyal contended that Section 22(4) is absolute and mandates transfer when cancellation grounds are raised. Garg did not contest the appeal, effectively conceding the suit should be transferred.
The dispute centers on whether the Commercial Court had discretion to assess the defense’s vagueness or whether it was bound to transfer the suit once such a defense was raised.
Discussion on Judgments
The judgment relies on the plain language of Section 22(4). Although no specific cases were cited in the document, a relevant precedent is Tobu Enterprises Pvt. Ltd. v. Megha Enterprises (2016 SCC OnLine Del 3510), which confirms that raising a cancellation ground necessitates transfer to the High Court.
Goyal’s counsel, Mr. Nishant Mahta, Mr. Junaid Alam, and Mr. S. Nithin, emphasized the mandatory nature of this provision. Garg’s counsel, Mr. Shivam Jangra, did not oppose the transfer, implying no conflicting jurisprudence.
Reasoning and Analysis of the Judge
The Division Bench delivered an oral judgment highlighting that the Commercial Court erred in not transferring the suit. Section 22(4) uses the word “shall”, leaving no room for judicial discretion. The court ruled that the refusal to transfer violated statutory procedure and rendered the interim injunction unsustainable.
Garg’s counsel did not oppose the order’s setting aside, which reinforced the procedural mandate’s clarity. The judgment stresses that statutory compliance is critical in intellectual property litigation.
Final Decision
On 24 July 2025, the High Court set aside the Commercial Court’s order and transferred the suit to the Intellectual Property Division. The Registry was directed to register the case and pending applications under appropriate numbers and notify the parties.
The High Court will now evaluate the design registration’s validity and the interim injunction on merits, as per the procedural rules under the Designs Act.
Law Settled in This Case
The ruling reinforces the mandatory nature of Section 22(4) of the Designs Act, 2000. It clarifies that trial courts cannot assess the strength of a cancellation defense before transferring a design infringement suit. The High Court has exclusive jurisdiction to adjudicate such challenges, ensuring uniformity and procedural rigor.
The decision protects defendants’ rights and reaffirms the judiciary’s role in upholding statutory mandates over discretionary interpretations at the trial level.
Case Title: Lalita Goyal vs. Sumit Garg
Date of Order: 24 July 2025
Case Number: FAO (COMM) 125/2025
Neutral Citation: 2025:DHC:6069-DB
Name of Court: High Court of Delhi
Judges: Hon’ble Mr. Justice C. Hari Shankar and Hon’ble Mr. Justice Om Prakash Shukla
Disclaimer: The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By: Advocate Ajay Amitabh Suman, IP Adjutor – Patent and Trademark Attorney
Email: [email protected], Ph no: 9990389539
