Lessons from INOX India Ltd. v. Cryogas Equipment Pvt. Ltd.”
Case name: INOX India Ltd. v. Cyrogas Equipment Pvt. Ltd.
Supreme Court citation: 2025 INSC 483
Civil Appeal Number: Civil Appeal No. 5174 of 2025
Abstract
The relationship between copyright law and design law in India has been an area of extreme complexity in intellectual property law. While copyright protects the original artistic creation, designs act protects the visual aspect of the product manufactured in the industry. The problem arises when the artistic drawing is incorporated into the industrial production process and there is a question whether the artistic work needs to maintain its status under the copyright law or move on to become a part of design law. The landmark judgment of the Supreme Court in the case of Inox India Ltd. v. Cryogas Equipment Pvt. Ltd. sheds light upon the matter by providing a systematic approach to deciding which law can apply in the case.
Introduction
Intellectual property law is aimed at protecting the process of creation and invention through the provision of exclusive rights to the respective creators and inventors. Often, problems emerge when two or more different types of intellectual property intersect and become overlapping. Such is the case when one compares the Copyright Act, 1957 and the Designs Act, 2000. Under copyright laws, protection applies to all original works of art, including drawings. In turn, design law protects visual characteristics of products produced by industries. Deciding what type of protection should apply becomes difficult in cases where technical drawings are employed for production purposes.
The issue is clarified through the landmark judgment of the Supreme Court in the case of Inox India Ltd. v. Cryogas Equipment Pvt. Ltd. provided a systematic approach to decide which law can be applicable in the case.
Facts
INOX India Limited manufactures cryogenic tanks and LNG semi-trailers specialised vehicles for transporting liquefied natural gas on Indian roads. To develop this INOX made certain technical and engineering drawings to help them manufacture their products. INOX claims that the drawings they made constitute artistic works.
Cryogas, which is the competitor company of INOX, has been accused by INOX of copyright infringement by using their drawings to make identical products.
INOX sought the infringement declaration, permanent injunctions, and damages of 2 crores.
Cryogas argues that the drawings made by INOX come under design and not artistic work and since the design has already been reproduced more than 50 times, INOX has lost its copyright according to section 15(2) of the Copyright Act.
The case traveled through the commercial court to the Gujarat high court and finally reached the supreme court.
Core questions
Whether Do the technical and engineering drawings made by INOX come under work in copyright or do the technical and engineering drawings made by INOX come under design, under the Design Act
Judgment
The Supreme Court formulated a two-pronged test. First, courts must determine whether the work is capable of registration under the Designs Act. Secondly, they must examine whether the features claimed are primarily aesthetic or purely functional. The Court clarified that copyright is not lost merely because a drawing is used in industrial production. Applying this framework, it upheld the Gujarat High Court’s decision and allowed the suit to proceed to trial.
Critical assessment
The judgment also builds upon earlier decisions dealing with the overlap between copyright and design protection by providing a structured framework where earlier courts had left the law uncertain.
The decision brings structure to Indian intellectual property law which did not previously exist. Previous cases acknowledged the overlap between copyright and design law but did not provide a clear answer as to when Section 15 of the Copyright Act would extinguish copyright protection. By mandating courts to evaluate both the registrability under the Designs Act as well as the functional or aesthetic nature of the work, the Supreme Court has curtailed the uncertainty over future disputes.
Cryogas’s anxiety was not all that unfounded, at the same time. Granting copyright protection to every industrial drawing would diminish the limited monopoly intended by the Designs Act. In response to this concern, the Court explained that purely functional features cannot be copyrighted merely because they appear in artistic drawings.
But there is still some uncertainty. Modern industrial products often have both functional utility and aesthetic appeal, and it is difficult to know which of the two should be given preference. Future judicial decisions will thus be important to refine the application of the two-pronged test.
Conclusion
The judgement delivered by the Supreme Court in the case of Inox India Ltd. v. Cryogas Equipment Pvt. Ltd. is an important milestone in the history of intellectual property law in India. In formulating a two-step approach, which considers whether a piece of work is registrable under the Designs Act and its functional and/or aesthetic aspect, the Court has given a useful criterion for deciding the conflicting claims of copyright and designs. In doing so, the Court has made sure that a piece of art is not automatically barred from copyright protection merely on the basis of its use in industry.
However, at the same time, there remain some areas where further decisions are required in regard to creations that embody aesthetic as well as functional qualities. This will be necessary, especially as developments in industrial technology will continue. Despite this caveat, the judgement will be helpful in bringing clarity and balance to the area of copyright and design law in India.
References
Prashant Reddy T., Part I: Cryogas Judgment — Supreme Court Stops Copyright from Gaslighting Design, SpicyIP, https://spicyip.com/2025/04/part-i-cryogas-judgment-supreme-court-stops-copyright-from-gaslighting-design.html.
Cryogas Equipment Pvt. Ltd. & Ors. v. Inox India Ltd., 2025 INSC 483 (Supreme Ct. of India 2025), https://indiankanoon.org/doc/170672552/.
Eashan Ghosh, Cryogas v. Inox: Copyright and Design Overlap, 20 Indian J.L. & Tech. (2025), https://repository.nls.ac.in/ijlt/vol20/iss2/5/.
Navigating the Crossroads of Copyright and Design: The Cryogas vs. Inox Saga, IPStars News & Analysis, https://www.ipstars.com/NewsAndAnalysis/navigating-the-crossroads-of-copyright-and-design-the-cryogas-vs-inox-saga/Index/10690
K&S Partners, Art Versus Functional Utility: The Intersection of Copyright and Design Laws, https://kandspartners.com/art-versus-functional-utility-the-intersection-of-copyright-and-design-laws/
Copyright Act, No. 14 of 1957, § 15(2) (India), https://www.copyright.gov.in/Documents/Copyrightrules1957.pdf.
Designs Act, No. 16 of 2000 (India), https://www.indiacode.nic.in/bitstream/123456789/1917/1/200016.pdf.
Drawing the Line Between Copyright and Design
Karishma Lokwani
DM Harish School of Law
Lessons from INOX India Ltd. v. Cryogas Equipment Pvt. Ltd.”
Case name: INOX India Ltd. v. Cyrogas Equipment Pvt. Ltd.
Supreme Court citation: 2025 INSC 483
Civil Appeal Number: Civil Appeal No. 5174 of 2025
Abstract
The relationship between copyright law and design law in India has been an area of extreme complexity in intellectual property law. While copyright protects the original artistic creation, designs act protects the visual aspect of the product manufactured in the industry. The problem arises when the artistic drawing is incorporated into the industrial production process and there is a question whether the artistic work needs to maintain its status under the copyright law or move on to become a part of design law. The landmark judgment of the Supreme Court in the case of Inox India Ltd. v. Cryogas Equipment Pvt. Ltd. sheds light upon the matter by providing a systematic approach to deciding which law can apply in the case.
Introduction
Intellectual property law is aimed at protecting the process of creation and invention through the provision of exclusive rights to the respective creators and inventors. Often, problems emerge when two or more different types of intellectual property intersect and become overlapping. Such is the case when one compares the Copyright Act, 1957 and the Designs Act, 2000. Under copyright laws, protection applies to all original works of art, including drawings. In turn, design law protects visual characteristics of products produced by industries. Deciding what type of protection should apply becomes difficult in cases where technical drawings are employed for production purposes.
The issue is clarified through the landmark judgment of the Supreme Court in the case of Inox India Ltd. v. Cryogas Equipment Pvt. Ltd. provided a systematic approach to decide which law can be applicable in the case.
Facts
INOX India Limited manufactures cryogenic tanks and LNG semi-trailers specialised vehicles for transporting liquefied natural gas on Indian roads. To develop this INOX made certain technical and engineering drawings to help them manufacture their products. INOX claims that the drawings they made constitute artistic works.
Cryogas, which is the competitor company of INOX, has been accused by INOX of copyright infringement by using their drawings to make identical products.
INOX sought the infringement declaration, permanent injunctions, and damages of 2 crores.
Cryogas argues that the drawings made by INOX come under design and not artistic work and since the design has already been reproduced more than 50 times, INOX has lost its copyright according to section 15(2) of the Copyright Act.
The case traveled through the commercial court to the Gujarat high court and finally reached the supreme court.
Core questions
Whether Do the technical and engineering drawings made by INOX come under work in copyright or do the technical and engineering drawings made by INOX come under design, under the Design Act
Judgment
The Supreme Court formulated a two-pronged test. First, courts must determine whether the work is capable of registration under the Designs Act. Secondly, they must examine whether the features claimed are primarily aesthetic or purely functional. The Court clarified that copyright is not lost merely because a drawing is used in industrial production. Applying this framework, it upheld the Gujarat High Court’s decision and allowed the suit to proceed to trial.
Critical assessment
The judgment also builds upon earlier decisions dealing with the overlap between copyright and design protection by providing a structured framework where earlier courts had left the law uncertain.
The decision brings structure to Indian intellectual property law which did not previously exist. Previous cases acknowledged the overlap between copyright and design law but did not provide a clear answer as to when Section 15 of the Copyright Act would extinguish copyright protection. By mandating courts to evaluate both the registrability under the Designs Act as well as the functional or aesthetic nature of the work, the Supreme Court has curtailed the uncertainty over future disputes.
Cryogas’s anxiety was not all that unfounded, at the same time. Granting copyright protection to every industrial drawing would diminish the limited monopoly intended by the Designs Act. In response to this concern, the Court explained that purely functional features cannot be copyrighted merely because they appear in artistic drawings.
But there is still some uncertainty. Modern industrial products often have both functional utility and aesthetic appeal, and it is difficult to know which of the two should be given preference. Future judicial decisions will thus be important to refine the application of the two-pronged test.
Conclusion
The judgement delivered by the Supreme Court in the case of Inox India Ltd. v. Cryogas Equipment Pvt. Ltd. is an important milestone in the history of intellectual property law in India. In formulating a two-step approach, which considers whether a piece of work is registrable under the Designs Act and its functional and/or aesthetic aspect, the Court has given a useful criterion for deciding the conflicting claims of copyright and designs. In doing so, the Court has made sure that a piece of art is not automatically barred from copyright protection merely on the basis of its use in industry.
However, at the same time, there remain some areas where further decisions are required in regard to creations that embody aesthetic as well as functional qualities. This will be necessary, especially as developments in industrial technology will continue. Despite this caveat, the judgement will be helpful in bringing clarity and balance to the area of copyright and design law in India.
References
Prashant Reddy T., Part I: Cryogas Judgment — Supreme Court Stops Copyright from Gaslighting Design, SpicyIP, https://spicyip.com/2025/04/part-i-cryogas-judgment-supreme-court-stops-copyright-from-gaslighting-design.html.
Cryogas Equipment Pvt. Ltd. & Ors. v. Inox India Ltd., 2025 INSC 483 (Supreme Ct. of India 2025), https://indiankanoon.org/doc/170672552/.
Eashan Ghosh, Cryogas v. Inox: Copyright and Design Overlap, 20 Indian J.L. & Tech. (2025), https://repository.nls.ac.in/ijlt/vol20/iss2/5/.
Navigating the Crossroads of Copyright and Design: The Cryogas vs. Inox Saga, IPStars News & Analysis, https://www.ipstars.com/NewsAndAnalysis/navigating-the-crossroads-of-copyright-and-design-the-cryogas-vs-inox-saga/Index/10690
K&S Partners, Art Versus Functional Utility: The Intersection of Copyright and Design Laws, https://kandspartners.com/art-versus-functional-utility-the-intersection-of-copyright-and-design-laws/
Copyright Act, No. 14 of 1957, § 15(2) (India), https://www.copyright.gov.in/Documents/Copyrightrules1957.pdf.
Designs Act, No. 16 of 2000 (India), https://www.indiacode.nic.in/bitstream/123456789/1917/1/200016.pdf.
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