Supreme Court Unifies Patent Disputes in Landmark IP Ruling

Supreme Court Unifies Overlapping Patent Disputes: A Landmark Ruling for IP Law in India

Atomberg vs Eureka Forbes sparks debate on forum shopping and judicial efficiency

Court clarifies “first in time” rule and rejects misuse of online purchases for jurisdiction

By Our Legal Reporter

New Delhi: October 25, 2025: In a landmark judgment delivered on 17 October 2025, the Supreme Court of India settled a crucial question in intellectual property (IP) law: how to handle overlapping disputes filed in different High Courts. The case, Atomberg Technologies Pvt. Ltd. vs Eureka Forbes Ltd., revolved around competing lawsuits—one alleging groundless threat of patent infringement in the Bombay High Court, and the other alleging patent infringement in the Delhi High Court.

The Supreme Court ruled that both cases should be consolidated and heard in the Bombay High Court, emphasizing judicial efficiency, consistency, and the principle that the first-filed suit deserves priority. This decision is expected to shape the future of IP litigation in India, especially in cases where rival companies file multiple suits across jurisdictions.

Background of the Dispute

Atomberg Technologies, a Mumbai-based company known for its energy-efficient appliances, launched a new water purifier called “Atomberg Intellon” in June 2025. The purifier featured advanced technology, including taste customization and Total Dissolved Solids (TDS) adjustment.

Soon after, Eureka Forbes, a leading player in the water purifier market, accused Atomberg of infringing its patents. It allegedly warned distributors and retailers that Atomberg’s product violated its proprietary technology. Atomberg saw these warnings as “groundless threats” under Section 106 of the Patents Act, 1970, and filed a suit in the Bombay High Court on 1 July 2025.

Eureka Forbes retaliated by purchasing Atomberg’s purifier online, receiving it in Delhi, and filing a patent infringement suit in the Delhi High Court on 7 July 2025. This created a situation where two overlapping cases—one in Bombay and one in Delhi—were pending simultaneously.

The Legal Battle Before the Supreme Court

Both companies approached the Supreme Court with transfer petitions:

Atomberg’s Petition (Civil No. 1983 of 2025): Requested transfer of the Delhi case to Bombay, arguing that both companies were headquartered in Mumbai and the Bombay suit was filed first.
Eureka Forbes’ Petition (Civil No. 2174 of 2025): Requested transfer of the Bombay case to Delhi, claiming that the infringement occurred in Delhi since the product was purchased and delivered there.

The Supreme Court had to decide which High Court was the proper forum and whether the two suits should be consolidated.

Supreme Court’s Reasoning

The Court, led by Justice Pamidighantam Sri Narasimha and Justice Atul S. Chandurkar, delivered a detailed analysis:

Independent Causes of Action:
- Under Section 106 of the Patents Act, a groundless threats suit is an independent cause of action, separate from an infringement suit.
- However, when both arise from the same product, patents, and parties, consolidation is justified to avoid duplication.
First in Time Rule:
- Atomberg’s Bombay suit was filed six days earlier than Eureka Forbes’ Delhi suit.
- The Court reaffirmed that the earlier-filed case should take precedence to prevent forum shopping.
Jurisdictional Concerns:
- The Court rejected Eureka Forbes’ argument that buying a product online in Delhi created valid jurisdiction.
- It held that such tactics cannot be used to artificially establish territorial jurisdiction.
Judicial Efficiency:
- Parallel proceedings would waste resources and risk conflicting judgments.
- Consolidation in Bombay was deemed more practical since both companies had offices there and the alleged threats originated in Mumbai.

The Verdict

The Supreme Court allowed Atomberg’s petition and ordered that the Delhi case be transferred to the Bombay High Court. Both suits will now be heard together as Commercial IP (L) No. 19837 of 2025.

Key directions included:

Eureka Forbes’ transfer petition was dismissed.
Both injunction applications (filed by Atomberg and Eureka Forbes) must be decided quickly by the Bombay High Court.
The ruling reaffirmed the importance of judicial efficiency and discouraged forum shopping.

Broader Implications for IP Law

This ruling has far-reaching consequences for intellectual property litigation in India:

Clarity on Section 106: The Court confirmed that groundless threats suits are valid and independent, but consolidation is necessary when disputes overlap.
Discouraging Forum Shopping: Companies can no longer manipulate jurisdiction by making token online purchases in different states.
Judicial Efficiency: The decision strengthens the principle that overlapping cases should be consolidated to save time and avoid contradictory rulings.
Boost for Innovation: By reducing uncertainty in IP disputes, the ruling may encourage companies to innovate without fear of prolonged litigation battles across multiple courts.

Expert Reactions

Legal experts have hailed the judgment as a progressive step in streamlining IP litigation. According to a one legal commentator, the Court’s reliance on Section 25 of the Civil Procedure Code (CPC) ensures that transfer of cases between High Courts is guided by fairness and efficiency.

Industry observers also note that this decision will likely influence future disputes in sectors like pharmaceuticals, technology, and consumer goods, where overlapping patent claims are common.

Conclusion

The Supreme Court’s ruling in Atomberg vs Eureka Forbes is more than just a resolution of a corporate rivalry. It sets a precedent for how India’s judiciary will handle overlapping IP disputes in the future. By prioritizing the first-filed case, rejecting artificial jurisdiction claims, and consolidating suits for efficiency, the Court has sent a strong message: justice must be consistent, efficient, and fair.

As India continues to grow as a hub for innovation and technology, this judgment will serve as a guiding light for both businesses and courts in navigating the complex world of intellectual property rights.