TVS Motor Company Limited v. Bajaj Auto Limited

A significant patent dispute clarifying the scope of interim injunctions and technical comparison in mechanical patent infringement cases.

Summary

This case involved a high-profile patent battle between two major Indian automobile manufacturers—TVS Motor and Bajaj Auto—regarding a digital twin-spark ignition (DTSi) technology. Bajaj claimed that its patented DTSi engine technology was copied by TVS in its “Flame” motorcycle model. TVS denied the allegation, arguing that its engine used a fundamentally different design. The dispute raised major questions about patent validity, technical comparison, and whether courts can grant interim injunctions without a full technical investigation.

Facts of the Case

Bajaj Auto held a patent for its DTSi technology involving a twin-spark plug system designed to improve combustion efficiency. When TVS introduced its “Flame” motorcycle using a two-spark plug configuration, Bajaj alleged direct patent infringement and approached the Madras High Court seeking an injunction. TVS countered that its technology used a completely different principle, relying on a three-valve system that operated differently from Bajaj’s patented method. Both sides presented expert reports, technical diagrams, and international prior art, making the dispute highly technical.

Findings / Court Reasoning

The Supreme Court held that such technically complex patent matters cannot be decided merely on prima facie impressions. The Court observed that a full trial with expert evidence was necessary before concluding whether the TVS engine truly infringed Bajaj’s patent. The Supreme Court criticized the grant of a premature injunction by the High Court, noting that mechanical patents often involve fine distinctions that cannot be assessed without detailed scientific scrutiny. The Court also emphasized that patent law aims to balance innovation incentives with fair competition.

Suggestions / Observations

The judgment encouraged courts to adopt a cautious approach while granting interim injunctions in patent disputes, especially when competing technologies appear similar but are technically different. The Court stressed the importance of expert testimony, prior art analysis, and detailed technical comparison before restricting commercial activities.

Judgment

The Supreme Court set aside the injunction against TVS and allowed it to manufacture and sell the “Flame” motorcycle until a final decision on infringement was reached. The matter was ultimately resolved through later proceedings, but the Supreme Court’s ruling remains a landmark precedent on interim relief in patent cases.