Graphical User Interfaces are registrable designs if they satisfy statutory criteria of industrial application and eye appeal.

The Appellants filed multiple statutory appeals under the Designs Act, 2000, challenging the rejection of their design applications for Graphical User Interfaces (GUIs) applied to various articles like display screens, vehicle dashboards, and electrosurgical generators

The Controller of Patents and Designs had rejected these applications on the grounds that a GUI does not constitute an "article" under Section 2(a), is not "applied" by an "industrial process" under Section 2(d), lacks "permanence" because it is only visible when the device is ON, and is protected as "artistic work" under the Copyright Act, thereby precluding dual protection

The Appellants contended that the 2021 Amendment to the Design Rules, which adopted the Locarno Classification including GUIs, signifies legislative intent to protect digital designs

The Court applied Section 2(a) defining "article" as any article of manufacture or substance

Section 2(d) defining "design" as features of shape, configuration, pattern, ornament, or composition applied to an article by any industrial process which appeal to the eye

The Court utilized the principle of "Updating Construction" to interpret statutes in light of technological advancements

relying on *State of Punjab v. Amritsar Beverages Ltd.* [(2006) 7 SCC 607]. It further relied on the "functional utility" test and the harmonization of Copyright and Design laws as established in *Cryogas Equipment Private Limited v. Inox India Ltd.* [2025 SCC Online SC 780] and Section 15 of the Copyright Act, 1957

Reference was also made to Rule 10(1) of the Design Rules, 2003 (as amended in 2021), which incorporates the Locarno Classification for "Screen Displays and Icons"

The Court reasoned that "article of manufacture" is a broad term encompassing digital devices and their display units

It rejected the Controller’s narrow interpretation of "industrial process," holding that the word "any" in Section 2(d) includes modern technical processes like rendering GUI via software and hardware

Applying "updating construction," the Court found that physical cogs are being replaced by digital signals, which nonetheless constitute industrial activity

Regarding permanence, the Court held that Section 2(d) does not require a design to be "permanently visible"; it is sufficient if the design is visible during the article's "normal use" (i.e., when turned ON)

On the issue of dual protection, the Court clarified that while a GUI's code is protected by copyright, its visual "look and feel" industrially applied to an article constitutes a "design."

Once industrially applied, it transitions from a pure "artistic work" to a "design" under the Act

The Court also noted that the Controller had previously registered several GUIs, creating an inconsistency in the Design Office's practice

The Court set aside the impugned orders and remanded the applications to the Controller for fresh consideration

It held that (i) GUIs can be "applied to an article"; (ii) digital rendering is an "industrial process"; (iii) "permanence" is not a statutory requirement; and (iv) the existence of copyright in the underlying code does not bar design registration of the visual interface

The appeals were allowed