On 18 May 2026 a Division Bench of the Delhi High Court, in Bansal v. Koninklijke Philips Electronics NV, set aside the 2018 single-judge SEP infringement decree by Justice Manmohan on Philips' DVD-related Indian Patent IN 184753 and articulated, for the first time at the Division Bench level in India, the evidentiary baseline a Standard-Essential Patent holder must meet at trial. The DB held that essentiality is a fact requiring proof through claim-charts mapped to the standard and through cross-examinable witnesses; that Philips' right was exhausted under Section 107A(b) of the Patents Act 1970 because the DVD components had been put on the market in China by Philips' authorised licensees; and that comparable-licence evidence is required to discharge the FRAND-rate burden. The ruling resets the FRAND-evidence architecture for the Ericsson, Nokia, Dolby and Malikie actions still on foot.