Mosaicing of Individual Elements from Multiple Prior Arts is Impermissible to Challenge Design Novelty or Originality

The Plaintiff, a prominent fan manufacturer, holds a valid design registration (No. 393299-001) dated 09.04.2024 for its "AEON" series ceiling fans

The Plaintiff alleged that the Defendant’s "GRACE" series ceiling fans infringed upon its registered design by replicating dominant visual features, including tapered blade geometry and hub structure

The Defendant contested the interim injunction, arguing that the Plaintiff’s design lacked novelty and originality, asserting that it was merely a "mosaicing" of various prior arts

the Defendant initially claimed a launch on 20.03.2026, but subsequent evidence suggested actual retail sales commenced only after the first court hearing on 30.03.2026

1. Whether the Plaintiff’s registered design lacks novelty/originality due to prior publication or mosaicing of known elements

2. Whether the Defendant’s "GRACE" series fan constitutes a piracy of the Plaintiff’s registered "AEON" fan design under Section 22 of the Designs Act

The court primarily applied the Designs Act, 2000, specifically Section 2(d) defining "design", Section 19 regarding grounds for cancellation, and Section 22 regarding piracy of registered designs

It relied heavily on the principles distilled in TTK Prestige Ltd. v. KCM Appliances Pvt. Ltd. (2023), which estabelece that "mosaicing" (combining individual elements of various prior designs) is impermissible to attack novelty; the design must be compared as a whole

the "instructed eye" test to assess ocular appeal and substantial novelty versus mere trade variants

The Court rejected the Defendant's challenge to novelty based on "prior art," observing that none of the seven cited prior arts, viewed as a composite whole, produced the same visual impression as the Plaintiff’s AEON fan

Following the TTK Prestige and Pidilite Industries (2024) precedents, the Court held that a design must be assessed in its entirety; therefore, the Defendant's attempt to isolate specific features (like blades or canopies) from different products to invalidate the Plaintiff's registration was legally untenable

Upon visual examination of the physical products, the Court found the "GRACE" fan to be unmistakably similar to the "AEON" fan in its sculpted, fluidic blade lines and motor-hub transition

Although minor differences existed in canopy shapes, the Court determined these were peripheral and did not overcome the replication of the essential novel features

The Court also took a stern view of the Defendant’s contradictory statements regarding the product launch, noting that the Plaintiff had approached the Court before actual retail sales had significantly commenced

The Court granted an interim injunction, restraining the Defendant from manufacturing, marketing, or selling the "GRACE" series or any deceptively similar fans

The Defendant was directed to cease further sales of existing stock from the date of the order and was ordered to file a shielded affidavit disclosing all sales records and financial statements related to the infringing product from 06.04.2026 onwards