Graphical User Interfaces (GUIs) are registrable designs under the Designs Act, 2000, satisfying "article" and "industrial process" criteria.

The appellants, including NEC Corporation, TVS Motor Company, and others, filed various applications for the registration of Graphical User Interfaces (GUIs) as designs under the Designs Act, 2000

The Controller of Patents and Designs rejected these applications through several impugned orders between 2019 and 2025

The rejections were primarily based on the grounds that a GUI is not 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 a device is switched ON, and is a functional software application protected under the Copyright Act rather than the Designs Act

The appellants challenged these orders, arguing for a broad, modern interpretation of the Act

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

Whether the lack of physical permanence (visibility only when the device is ON) or the involvement of software codes disqualifies a GUI from being "applied to an article by an industrial process"

The court applied Section 2(a) of the Designs Act, 2000, which defines "article" as any article of manufacture or substance

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

The court utilized the principle of "updating construction" to account for technological changes since enactment

It further relied on *Samsung Electronics Co. Ltd. vs. Apple Inc.* regarding the broad definition of "article"

The court relied on *Cryogas Equipment Private Limited vs. Inox India Ltd.* regarding the interface between the Copyright Act and the Designs Act

The court reasoned that the term "article" in Section 2(a) is broad and not limited to physical/tangible embodiments that exist independently of digital forms

It held that the "industrial process" mentioned in Section 2(d) is preceded by the word "any," indicating an inclusive scope that encompasses modern digital rendering and electronic manipulation of signals

The court rejected the "permanence" requirement, noting that Section 2(d) does not mandate a design be "permanently visible"; a design is registrable if visible during the article's intended use, such as a display screen being turned ON

Regarding dual protection, the court clarified that while the underlying code is a computer program/literary work, the visual GUI applied to an article for industrial purposes represents a distinct design feature

Finally, the court noted that the 2021 amendment to the Design Rules, adopting the Locarno Classification (Class 14-04), evidenced a clear administrative intent to recognize GUIs

The court concluded that the respondent authorities applied overly narrow and hyper-technical tests

Consequently, all appeals were allowed, the impugned orders were set aside, and the matters were remanded to the Controller for fresh consideration on a case-by-case basis after providing the appellants an opportunity to be heard