A patent claim cannot be rejected by mosaicing prior arts without establishing a reasoned connection.

The North Face Apparel Corp. applied for an Indian patent for “Systems and Methods for End-to-End Article Management.”

Following examination and hearings, the Controller rejected the application, finding that the claimed invention lacked an inventive step in view of prior-art documents D21–D24.

The applicant appealed under Section 117A of the Patents Act, 1970, arguing that the Controller had improperly combined and compared isolated features of the cited documents and had overlooked the invention’s use of spectrophotometers and invisible markers for tracking and correcting manufacturing discrepancies.

The Controller maintained that the documents, read together, disclosed the claimed subject matter.

1. Whether the Controller’s finding that the claimed invention lacked an inventive step, based on D21–D24, was sustainable

2. Whether the Court should set aside the refusal and direct grant of the patent

The appeal was brought under Section 117A of the Patents Act, 1970, which provides for an appeal against specified orders of the Controller.

The Court applied the statutory concept of “inventive step,” describing it as involving a technical advance over existing knowledge or economic significance, or both, and also referred to the requirement of industrial applicability.

The Court further considered the principles governing comparison with prior art, including that a claimed invention must be assessed as a whole and that prior-art teachings cannot be combined through hindsight.

The Court found that, despite the Controller’s assertion that the claim had been assessed as a whole, the impugned order and the respondent’s counter effectively compared features of the invention against the cited documents individually.

The cited documents had different objectives and did not disclose the claimed process of identifying articles through invisible markers detected by a spectrophotometer; the Court also noted that D21 did not address detection or correction of manufacturing errors, while D22 concerned optically readable codes.

The Court concluded that the documents, whether considered separately or together, did not establish that the claimed combination arose from common general knowledge, and that combining them to reject the claim involved an insufficiently supported reconstruction.

It therefore found that the claimed process embodied an inventive step and that the Controller had overlooked this feature.

It allowed the appeal, set aside the Controller’s order dated 16 April 2025, and directed the Controller to grant the patent for Indian Patent Application No. 202147026139.

There was no order as to costs.