Interim injunction sustained where prima facie case exists and trial is directed for time-bound completion.

The Appellants (Defendants) challenged an interim injunction order dated 11.06.2025 passed by the Commercial Court, Vadodara, in Trade Mark Suit No. 3 of 2019.

The Plaintiff (Respondent No. 1) claimed copyright over Proprietary Engineering Drawings for cryogenic semi-trailers, allegedly acquired from a US-based company and subsequently improved upon.

The Defendants contended that the designs were in the public domain under the Static and Mobile Pressure Vessel (unfired) Rules, 2016, and that copyright had ceased under Section 15(2) of the Copyright Act due to industrial application.

The High Court noted the Supreme Court had previously directed the trial to conclude by October 2026.

1. Whether the Plaintiff established a prima facie case and balance of convenience for the grant of an interim injunction regarding copyright infringement of engineering drawings.

2. Whether the appellate court should interfere with the discretionary interim order of the Trial Court when the trial is already at an advanced stage of evidence.

Requirements for original artistic and literary works under Section 13(1)(a) of the Copyright Act, 1957.

Section 15(2) of the Copyright Act, which terminates copyright once a design is reproduced more than fifty times by an industrial process if it is capable of registration under the Designs Act, 2000.

Section 52(1)(w) of the Copyright Act, which provides that making three-dimensional objects from two-dimensional technical drawings for functional industrial application does not constitute infringement.

Procedural standards for Order XXXIX Rules 1 and 2 of the CPC and Section 13 of the Commercial Courts Act, 2015.

The Court declined to perform a "mini-trial" to resolve the technical arguments regarding whether the drawings were in the public domain or if the Plaintiff had sufficiently proved the acquisition of Intellectual Property from the US company.

It held that the Trial Court had provided adequate reasoning to show that a prima facie case existed and the balance of convenience tilted in favor of the Plaintiff.

The Court emphasized that because the trial was already at the stage of evidence—with the Plaintiff's examination-in-chief complete—and was under a strict time-bound mandate from the Supreme Court to finish by October 2026, interfering with the interim arrangement was unnecessary.

The Appellants’ arguments regarding irreparable loss were deemed secondary to the advanced stage of the suit and the existing judicial findings.

It directed the Trial Court to conclude the proceedings within the timeline prescribed by the Supreme Court (by October 2026) without granting unnecessary adjournments.

The Court clarified that the Trial Court must independently evaluate the merits of the evidence during the final disposal, unaffected by observations made at the interim stage.