When monopoly ends, enforcement ends with it—except where past infringement leaves a financial trail. A decisive ruling on the limits of judicial relief after patent expiry, clarifying why exclusivity ends with the statutory term but monetary accountability for past infringement does not.
In a significant intellectual property law ruling, the Delhi High Court has clarified how patent rights in India must be treated once the statutory term of a patent expires. The case between Kabushiki Kaisha Toyota Jidoshokki (Toyota) and LMW Limited (LMW) offers key lessons on whether courts can grant injunctive relief after a patent expires and what remedies remain available to patentees.
Factual Background
Toyota, a global engineering company, held Indian patent IN759, among others, relating to technology used in textile spinning machinery. Toyota alleged that LMW’s product “Spinpact” incorporated features covered by its patents and sought interim injunctions to restrain LMW from continuing alleged infringing activities.
However, during the pendency of Toyota’s application for interim relief, patent IN759 expired on 24 May 2025, after completing the twentyyear statutory term prescribed under Section 53 of the Patents Act, 1970.
This Article is a Part of Our The Ultimate Guide to Intellectual Property Law.
Statutory Framework: Patent Term and Public Domain
Under Section 53(1) of the Patents Act, the term of a patent in India is limited to twenty years from the filing date, after which the patent “shall cease to have effect”. Once this term lapses, the patented invention enters the public domain, permitting unrestricted use by any person.
In the Toyota v. LMW proceedings, the Delhi High Court emphasised that this statutory timeline is conclusive, and there is no mechanism under Indian law to extend or renew a patent beyond its twentyyear term.
Delhi High Court Holding
On 1 July 2025, a singlejudge bench of the Delhi High Court, led by Justice Saurabh Banerjee, dismissed Toyota’s application for interim injunction against LMW on the simple ground that IN759 had expired and therefore no enforceable patent right existed to support injunctive relief.
The Court observed that granting any form of injunction to restrain the use or manufacture of a technology that is no longer under patent protection would be “futile, anomalous, and beyond statutory sanction.” Courts cannot grant relief that the statute in this case the Patents Act does not provide.
The ruling highlights a fundamental principle of patent law in India: exclusive rights under a patent are conferred only for its statutory term. Once the term lapses, the monopoly expires and the invention becomes part of the public domain.
Interim Injunctions and Expired Patents
A central question in the case was whether courts could issue interim injunctions after patent expiry to address ongoing use or manufacture of the technology. The Delhi High Court’s answer was emphatic: injunctions cannot be granted postexpiry because no enforceable statutory right remains after the patent term ends.
This reasoning aligns with the statutory text of Section 53 and with established patent doctrine that injunctive relief protects existing exclusive rights; if the right no longer exists, there is nothing to enforce.
The Court’s refusal to delve into infringement merits in the interim context underscored that postexpiry injunctive relief would amount to reviewing a right that has already ceased to exist.
Residual Remedies After Expiry
Although injunctions were refused, the Delhi High Court did not dismiss Toyota’s entire case. Instead, it allowed the underlying infringement suit to proceed on other fronts, notably:
- Whether LMW had infringed Toyota’s patent during the period when it was in force; and
- The extent of damages or account of profits attributable to any infringement that occurred before patent expiry.
The Court directed LMW to file an affidavit detailing sales, profits, and stock movements related to allegedly infringing products up to the date of patent expiry (24 May 2025), to assist in evaluating potential monetary remedies at trial.
This reflects the principle that while exclusive rights end with expiry, rights to compensation for past infringement can still be pursued through damages or accounting, provided the infringement occurred during the life of the patent.
Policy Underpinnings and Broader Implications
The Court’s reasoning draws on the balance patent law seeks between private monopoly and public benefit. The twentyyear term is deliberately calibrated to reward innovators while ensuring that, postexpiry, patented technology enriches the public domain for broader economic and social benefit.
Granting injunctions beyond this term would impinge on this policy by effectively permitting perpetual exclusivity, contrary to the statutory scheme.
For patentees and litigators, the Toyota v. LMW decision sends a clear message:
- Patentees must enforce rights promptly within the statutory term if they seek injunctive protection;
- Claims for injunctive relief after expiry are legally untenable;
- Monetary remedies remain viable for infringement occurring while the patent was in force; and
- Courts will not entertain substantive adjudication on infringement where the underlying right has ceased.
Comparative Context
Similar principles have been acknowledged in other patent disputes where expiry negated injunctive relief, emphasising that interlocutory protection must be tied to a subsisting right. Courts routinely refuse injunctions postexpiry as inherently incapable of effective enforcement.
Thus, the Toyota v. LMW ruling aligns with a consistent jurisprudential theme: patent exclusivity is finite, and relief mechanisms reflect this temporal constraint.
Patent Expiry and the Limits of Judicial Relief
The Delhi High Court’s decision in Toyota v. LMW Limited conclusively addresses a critical question in Indian patent law: Can a patent rescue relief after expiry? The answer in India today is not a patent’s statutory expiry extinguishes enforceable rights, and courts cannot grant injunctions based on an expired monopoly. However, patentees retain the ability to pursue monetary remedies for past infringement, underscoring that while exclusivity is timebound, accountability for prior misuse remains enforceable.
