Graphical User Interfaces (GUIs) are registrable designs satisfying the statutory criteria of "article" and "industrial process."

The Appellants filed various statutory appeals under the Designs Act, 2000, challenging orders passed by the Controller and Assistant Controller of Patents and Designs which rejected applications for the registration of Graphical User Interfaces (GUIs) as designs.

The rejections were primarily based on the grounds that: (i) a GUI does not qualify as an "article" under Section 2(a) because it is software-based and lacks a physical embodiment;

(ii) a GUI is not "applied" by an "industrial process" as defined in Section 2(d);

(iii) a GUI lacks "permanence" because it is only visible when a device is switched ON;

and (iv) GUIs are better protected as "artistic works" under the Copyright Act, 1957.

1. Whether a Graphical User Interface (GUI) satisfies the statutory criteria of a "design" and "article" making it eligible for registration under the Designs Act, 2000?

2. Whether the term "industrial process" under Section 2(d) of the Act includes digital or electronic processes used to display a GUI?

3. Whether the requirement of "permanence" or "physical touch" is a mandatory prerequisite for design registration under the Act?

The Court primarily interpreted Section 2(a) (“article”) and Section 2(d) (“design”) of the Designs Act, 2000.

It applied the principle of "updating construction" to interpret statutes in light of technological advancements, as supported by *Bennion on Statutory Interpretation* and *State of Punjab v. Amritsar Beverages Ltd.*

It relied on *Samsung Electronics Co. Ltd. v. Apple Inc.* and *Microsoft Corp. v. Corel Corp.* to define "article of manufacture" broadly.

Regarding the "eye appeal" and visibility during use, the court referenced *K.K. Suwa Seikosha’s Design Application* and *In re: Hruby*.

To resolve the overlap with copyright, the court applied the two-pronged test from *Cryogas Equipment (P) Ltd. v. Inox India Ltd.*

It further noted the administrative relevance of the Locarno Classification (Class 14-04) as adopted in Rule 10(1) of the Design Rules, 2003.

The Court reasoned that Section 2(a) and 2(d) must be construed liberally and purposively to include digital designs.

It held that a GUI is not the "article" itself but a feature (shape, pattern, or ornament) "applied to an article" (such as a display screen or dashboard), and thus the two are distinct.

The Court rejected the Controller's narrow interpretation of "industrial process," holding that the word "any" in Section 2(d) indicates that the listed processes (manual/mechanical/chemical) are not exhaustive.

Using the doctrine of "updating construction," the Court found that the electronic rendering of a GUI constitutes a modern industrial process.

Furthermore, the Court dismissed the requirement for "permanence," stating that Section 2(d) only requires the design to be visible when the article is used for its intended purpose.

The Court clarified that while a GUI is generated by software, it is the *visual interface* (the "look") that is sought to be registered as a design, not the underlying code, thereby avoiding dual protection conflicts with the Copyright Act as long as the design is applied industrially.

It concluded that a GUI can be registered if it meet the criteria of being applied to a finished article, judged solely by the eye, and is not purely functional.

The Court set aside all the impugned rejection orders and remanded the applications to the Controller for fresh consideration on a case-to-case basis in light of the legal findings.

All connected appeals (IPDAID/21/2024, IPDAID/22/2024, IPDAID/1/2025, IPDAID/2/2025, IPDAID/3/2025) were allowed.