ValkyaEditorial

Tagged “section-48”

2 articles on section-48.

Landmark JudgmentNational Company Law Appellate Tribunal

Keshav Bihani v. CCI: NCLAT upholds the Railways polyacetal-tubes cartel penalty and clarifies Section 48 individual liability

NCLAT Principal Bench dismisses appeals against CCI's bid-rigging finding on the polyacetal protective-tubes suppliers to Indian Railways; reads 'punished accordingly' in Section 48(1) of the Competition Act 2002 (pre-2023 Amendment) to mean the individual penalty must match the enterprise penalty in scale, applied to the active partner's income.

Valkya Editorial··10 min
Landmark JudgmentDelhi High Court

F. Hoffmann-La Roche v. Cipla: Section 3(d) is a patent-eligibility provision at grant, not an infringement defence

On 27 November 2015 a two-judge Division Bench of the Delhi High Court (Pradeep Nandrajog, J. and Mukta Gupta, J.) delivered the long-awaited decision on Roche's IN 196774 — the Indian patent on Erlotinib Hydrochloride, sold as Tarceva — and Cipla's accused generic Erlocip. The Bench held the suit patent valid, held Cipla's Polymorph B product within the scope of the compound patent (the failure of Roche's downstream Polymorph B claim under *Section 3(d)* did not narrow the parent compound patent), declined a permanent injunction because the patent was within months of expiry, and — most consequentially — held that *Section 3(d)* of the *Patents Act 1970* is a patent-eligibility provision operating at the grant stage and is not available as a defence at the infringement stage. The decision imposed ₹5 lakh in costs on Cipla and remanded for an accounts inquiry. The Special Leave Petition was admitted in 2016 and withdrawn under settlement in June 2017; the Delhi Bench's framework remains good law.

Valkya Editorial··14 min