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Introduction
In December 2025, the Madras High Court delivered a significant judgment in Titan Company Limited v. The Controller of Patents & Designs (C.M.A.(PT) No. 44 of 2024). The case arose from the rejection of Titan’s patent application for a jewellery assembly. The Court’s ruling clarified the scope of Section 3(l) of the Patents Act, 1970, which excludes “aesthetic creations” from patentability, and emphasized that inventions with technical features must be evaluated on their merits. This judgment is particularly important for industries such as jewellery, where aesthetic appeal and technical innovation often overlap, and it reinforces the principle that authorities must issue comprehensive orders that address all submissions before rejecting an application.
Facts of the Case
Titan Company Limited filed Patent Application on 4 February 2020 for an invention titled “A Jewellery Assembly.” The invention involved a structural configuration comprising a base member with multiple walls and an inclined cavity designed to hold a central gemstone. Around this central stone, elongated peripheral gemstones were arranged to secure it in place. The arrangement created the appearance of a single square-shaped gemstone, even though it was composed of multiple smaller stones.
On 6 February 2024, the Controller of Patents rejected the application. The rejection was based on Section 3(l) of the Patents Act, which excludes aesthetic creations from patentability. The Controller concluded that the invention was more suited for registration under the Designs Act, 2000. Titan appealed this decision under Section 117A of the Patents Act, which provides a statutory right of appeal against orders of the Controller. The High Court reserved judgment on 13 October 2025 and pronounced its decision on 11 December 2025, setting aside the rejection and remanding the matter for fresh consideration.
Argument in Favour
Titan argued that its invention was technical in nature and not merely aesthetic. The company emphasized that the invention solved a cost-related problem in jewellery manufacturing by using smaller, less expensive gemstones arranged structurally to create the illusion of a large diamond. This provided an affordable solution without compromising visual appeal. Titan further contended that the inclined cavity and gemstone arrangement ensured stability and durability, which were functional features rather than ornamental ones.
The appellant maintained that the Controller had misinterpreted the law by conflating the Patents Act with the Designs Act. Section 3(l) excludes aesthetic creations, but Titan’s invention involved constructional features. Section 2(d) of the Designs Act defines “design” as features judged solely by the eye, excluding constructional or mechanical aspects. Titan argued that its invention fell outside this definition because it involved structural innovation. The company also pointed out that the Controller had failed to consider its written submissions and had ignored the technical claims, resulting in a rejection order that lacked detailed reasoning.
Argument Against
The Controller of Patents defended the rejection order by asserting that the invention did not solve any technical problem and was primarily aesthetic, designed to enhance appearance. The respondent argued that the invention was a mere workshop improvement, lacking inventive step, and therefore did not meet the threshold required for patent protection. The features, according to the Controller, related to shape and appearance, making them more suitable for protection under the Designs Act, 2000.
Court’s Decision
The Madras High Court set aside the rejection order and remanded the matter for fresh consideration. The Court observed that the Controller had failed to consider Titan’s submissions and ignored the technical aspects of the invention. This amounted to a denial of natural justice.
The Court clarified the distinction between patents and designs. Section 3(l) of the Patents Act excludes aesthetic creations from patentability, while Section 2(d) of the Designs Act defines “design” as features judged solely by the eye, excluding constructional or functional aspects. Titan’s invention involved constructional features and therefore could not be dismissed as a mere design. The Court emphasized that orders of the Controller must address all objections raised, even if rejection is based on one ground, to ensure proper judicial review.
Legal Provisions
Section 3(l) of the Patents Act, 1970 excludes “aesthetic creations” from patentability. This provision ensures that patents are granted only for technical inventions and not for purely ornamental features. Section 117A of the Patents Act provides a statutory right of appeal against orders of the Controller, which Titan exercised in this case. Section 2(d) of the Designs Act, 2000 defines “design” as features judged solely by the eye, excluding constructional or mechanical aspects. This distinction was crucial in determining whether Titan’s invention was a design or a patentable invention.
Cited Cases
The Court referred to several precedents to support its reasoning. In Avery Dennison Corporation v. Controller of Patents and Designs (Delhi High Court, 4 November 2022), it was held that technical advancements not obvious to a person skilled in the art satisfy the test of inventive step. This case was cited to support Titan’s claim that its structural arrangement was a technical advancement.
In Dura-Line India Pvt Ltd. v. Jain Irrigation Systems Ltd. (Delhi High Court, 19 May 2025), the Court recognized that functional and constructional features are technical aspects falling within patent registration. This precedent was cited to show that Titan’s invention involved functional features beyond mere aesthetics.
The respondent relied on M/s. Bishwanath Prasad Radhey Shyam v. Hindustan Metal Industries ((1979) 2 SCC 511), which held that a patentable invention must be more than a mere workshop improvement. The High Court distinguished Titan’s invention from this precedent, noting that it involved structural innovation rather than a simple workshop improvement.
Finally, in Adama Makhteshim Ltd. v. Controller of Patents (Delhi High Court, 1 May 2023, C.A.(COMM.IPD-PAT) 167/2022), it was held that a Controller’s order must be comprehensive and examine all grounds of objection to facilitate judicial review. This case was cited to reinforce the Court’s finding that the rejection order was unsustainable due to lack of detailed reasoning.
Conclusion
The 2025 judgment of the Madras High Court in Titan Company Limited v. Controller of Patents & Designs has become a landmark ruling in patent law. It observes that inventions with technical features cannot be dismissed as aesthetic creations under Section 3(l) of the Patents Act. The Court stated that authorities must carefully distinguish between patents and designs and must issue comprehensive orders addressing all objections.
For industries such as jewellery, where design and functionality often intersect, this judgment provides clarity. Technical innovations embedded in aesthetic products can qualify for patent protection. The judgement observes the rights of innovators, ensuring that inventions combining artistry with engineering are not denied protection merely because they also possess visual appeal. By remanding the matter, the Court ensured that Titan’s application would be reconsidered with due attention to its technical claims.
