Industrial design law plays a crucial role in protecting the aesthetic features of products that appeal to consumers. In India, industrial designs are governed by the Designs Act, 2000 and the Designs Rules, 2001. The purpose of design protection is to safeguard the unique visual appearance of articles and prevent competitors from copying the ornamental or aesthetic aspects of products. Judicial decisions interpreting these provisions have shaped the contours of design law in India, clarifying principles such as novelty, originality, functionality, prior publication, and infringement.

Over the years, Indian courts have decided several important design cases across industries such as consumer goods, packaging, glass products, automobiles, furniture, fashion items, and home décor. These cases provide valuable insights into how courts interpret the Designs Act and how businesses can better protect their innovations.

This article provides a comprehensive discussion of the most famous Indian design cases, examining their facts, legal issues, decisions, and their impact on Indian design jurisprudence.

I. Bharat Glass Tube Ltd. v. Gopal Glass Works Ltd. (2008)

Supreme Court of India

This case is one of the most significant judgments relating to design law in India.

Facts

Bharat Glass Tube Ltd. marketed patterned glass sheets. Gopal Glass Works Ltd. claimed infringement of its registered design applied to the pattern on the glass sheets. Bharat Glass argued that the design lacked novelty and was already published internationally.

Legal Issue

Whether the design was new and original, and whether international prior publication invalidated the design.

Court’s Reasoning

The Supreme Court held:

1. Novelty lies in visual appeal, not in functional use.
2. The pattern applied to the glass sheet had not been proven to be previously published in India.
3. The design possessed distinct ornamental features that appealed to the eye.
4. International publication must be proven with clear evidence to invalidate a registered design.

Impact

This case strengthened design protection by emphasising visual appeal as the primary test for novelty and clarified the burden of proof for prior publication.

II. Micro Fibres Inc. v. Girdhar & Co. (2006)

Delhi High Court

This case clarified the relationship between design law and copyright law.

Facts

Micro Fibres Inc. manufactured fabrics with artistic designs. These designs were applied to industrial goods more than 50 times. They filed a suit alleging copyright infringement.

Legal Issue

Whether fabric designs applied industrially can claim copyright or must be registered under the Designs Act.

Court’s Reasoning

The Delhi High Court held:

1. Once an artistic work is applied to more than 50 articles, copyright protection ceases, and the design must be protected under the Designs Act, 2000.
2. The purpose of the Designs Act is to prevent dual protection—copyright and design—for industrially applied designs.
3. The plaintiff did not have design registration, so no remedy was available under design law.

Impact

This case reinforced Section 15 of the Copyright Act, clarifying that mass-produced designs fall exclusively under design law.

III. B. Chawla & Sons v. Bright Auto Industries (1981)

Delhi High Court

This case is a landmark decision explaining originality in designs.

Facts

B. Chawla & Sons manufactured rear-view mirrors for automobiles. Bright Auto Industries allegedly copied their mirror design.

Legal Issue

Whether applying a known shape to a specific article can constitute originality.

Court’s Reasoning

The Court held:

1. Even if design elements exist in nature or previous articles, novelty can lie in the application to a new article.
2. The overall visual impression must be considered.
3. Minor differences are enough if the overall effect on the eye is distinctive.

Impact

This case broadened the understanding of originality in design registration.

IV. Whirlpool of India Ltd. v. Videocon Industries Ltd. (2014)

Bombay High Court

This case clarified the distinction between aesthetic and functional features.

Facts

Whirlpool sued Videocon for infringing the design of its refrigerator door handle. Videocon argued that the design was purely functional.

Legal Issue

Whether the handle design was aesthetically significant or dictated solely by function.

Court’s Reasoning

The Court held:

1. Features dictated solely by function cannot be protected under design law.
2. The handle design had both functional and aesthetic elements, but its functional aspect dominated, making it ineligible for design protection.
3. The design was not new, as similar handles existed in the market.

This case strengthened the principle under Section 2(d) that designs must be primarily ornamental, not functional.

V. Steelbird Hi-Tech India Ltd. v. S.P.S. Gambhir (2014)

Delhi High Court

This case reaffirmed protection against imitation in consumer goods.

Steelbird, a well-known helmet manufacturer, registered the design of its helmet. Gambhir was accused of selling helmets with a deceptively similar design.

Whether the defendant’s helmets were visually similar and constituted piracy under Section 22.

The Court held:

1. The designs were visually similar and likely to confuse an ordinary viewer.
2. Registration provides exclusive rights, and other manufacturers cannot imitate or apply similar designs.
3. Injunctions were necessary to prevent dilution of design rights.

The case strengthened enforcement of registered designs and emphasised the ordinary observer test.

VI. Carlsberg Breweries v. Som Distilleries and Breweries Ltd. (2019)

Delhi High Court

One of the most influential modern design cases, especially regarding composite suits.

Carlsberg claimed that Som Distilleries copied the bottle design used for its popular beverage. They filed a composite suit for:

• design infringement, and
• passing off.

Whether courts can entertain a composite suit combining design infringement and passing off.

The Court held:

1. A composite suit is maintainable when the cause of action arises from the same facts.
2. Design infringement and passing off are distinct but related remedies.
3. Designs protect visual features, while passing off protects business reputation.

This judgment clarified the coexistence of design rights and trademark rights, promoting stronger brand protection.

VII. Dabur India Ltd. v. Amit Jain (2009)

Delhi High Court

This case explains the overlap between design and trademark law.

Dabur claimed that Amit Jain copied the packaging of its toothpaste. Dabur asserted design rights and passing off.

Whether packaging similarity could constitute both design infringement and passing off.

The Court held:

1. Design law protects aesthetic elements; passing off protects reputation.
2. The defendant’s packaging created visual similarity, amounting to design piracy.
3. Additionally, the packaging caused deception among consumers.

This case helped clarify how design and trademark disputes may intersect.

VIII. Britannia Industries Ltd. v. ITC Ltd. (2016)

Delhi High Court

This case set an important precedent regarding design originality.

Both Britannia and ITC sold rectangular biscuits with patterned designs. Britannia claimed that ITC’s “Sunfeast” biscuits copied the design of its “Good Day” biscuits.

Whether small alterations to a common shape can create an original design.

The Court held:

1. Commonplace shapes (such as rectangles) cannot be monopolised.
2. Originality lies in the overall arrangement of the design features.
3. ITC’s biscuit had sufficient differences and did not infringe Britannia’s design.

The judgment clarified that minor design differences can eliminate infringement if they create a new visual impact.

IX. Diageo Brands B.V. v. Khoday India Ltd. (2016)

Delhi High Court

This case concerns bottle shape design protection.

Diageo, the owner of the iconic “Johnnie Walker” bottle design, sued Khoday India for imitation of bottle shape.

Whether bottle shapes can be protected as designs when they also function as trademarks.

The Court held:

1. Bottle shapes are eligible for design protection if they have aesthetic elements.
2. A bottle shape can acquire distinctiveness as a trademark.
3. Here, Diageo proved both design originality and trademark reputation.

This case illustrated the overlap between design and trademark protection and validated protection for distinctive packaging shapes.

X. S.S. Rubber Industries v. Bhagwati Rubber Udyog (2014)

Delhi High Court

This case highlights the importance of novelty and prior publication.

S.S. Rubber claimed exclusive rights over a tyre tread design. Bhagwati Rubber challenged the design, citing prior publication.

Whether the design was already known before registration.

The Court held:

1. Tread designs are often published or used in the industry.
2. The plaintiff failed to prove novelty.
3. Prior publication invalidated the design.

The case reinforced the principle that prior publication destroys novelty, making design registration invalid.

XI. Cello Household Products v. Modware India (2022)

Bombay High Court

A modern case involving household plastic products.

Cello alleged copying of its water bottle design by Modware. The similarity was in shape, colour combinations, and pattern.

Whether colour combinations form part of design protection under Section 2(d).

The Court held:

1. Design registration covers shape and configuration, but colour combinations may be relevant only when applied as ornamentation.
2. Visual similarity must be judged from an ordinary observer’s perspective.
3. Modware’s design was confusingly similar.

This case showcased how courts apply modern interpretations for common consumer goods.

XII. Philips India v. Remington (2016)

Delhi High Court

A case involving design protection for grooming devices.

Philips claimed that the design of its trimmer was copied by Remington.

Whether design registration for the trimmer was valid and infringed.

The Court held:

1. Trimmers can have ornamental shapes beyond functional necessity.
2. Remington’s product created deceptive similarity.
3. Philips was entitled to injunction.

The judgment expanded design protection for consumer electronics.

XIII. Gillette India v. M/S Precision (2015)

Delhi High Court

This case concerns design protection for razors.

Gillette claimed that Precision copied its razor design.

Whether the design was functional or ornamental.

The Court held:

1. The razor design had significant ornamental features.
2. Functionality alone does not invalidate a design if aesthetic elements exist.
3. Precision’s design was deceptively similar.

The case reinforced that products with functional utility can still enjoy design protection if decorative elements are present.

XIV. Key Principles Emerging from Famous Indian Design Cases

From these landmark judgments, several legal principles have emerged:

1. Visual Appeal Is Central

Courts evaluate designs based on how they appear to the ordinary observer, not experts.

2. Functionality Is Excluded

Purely functional features cannot be protected (Whirlpool v. Videocon).

3. Prior Publication Destroys Novelty

Any public disclosure, anywhere in the world, can invalidate a design (Bharat Glass Tube case).

4. Minor Differences May Establish Originality

If the overall impression differs, originality may be upheld (Britannia v. ITC).

5. Composite Suits Are Allowed

Design infringement and passing off can be combined (Carlsberg case).

6. Overlap with Copyright and Trademark Must Be Managed

Dual protection is limited by Section 15 of the Copyright Act (Micro Fibres case).

7. Design Enforcement Is Strong When Registration Is Clear

Cases like Steelbird and Cello show strong enforcement when novelty is well-defined.

Conclusion

The evolution of design law in India has been shaped significantly by judicial decisions across a wide range of industries. The Designs Act, 2000 provides the legal framework for protecting aesthetic creations, but it is the courts that interpret and apply this law in real-world disputes. Famous Indian design cases—from Bharat Glass Tube and Micro Fibres to Carlsberg Breweries and Britannia Industries—have clarified important principles such as novelty, originality, prior publication, functionality, and the test of visual similarity. These decisions help designers, entrepreneurs, manufacturers, and businesses understand the value and limitations of design rights.

Design jurisprudence in India continues to grow as new industries emerge, especially in lifestyle products, consumer electronics, fashion, and packaging. As India becomes a global manufacturing and innovation hub, understanding design protection and studying famous cases becomes essential for safeguarding creativity and strengthening market competitiveness.