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Case note

Agriboard International LLC v. Deputy Controller of Patents and Designs

The question before the court

How much reasoning a Controller's order must contain when an application is refused for lack of inventive step.

What the court held

The Court quashed the order and remitted the matter to the Controller for a fresh decision. It held that an order refusing a patent for obviousness must do three things: say what the cited prior art actually discloses, say what the features of the claimed invention are, and explain why a skilled person would find the step obvious in light of that prior art. Repeating the examination report, or simply asserting obviousness, is not a reasoned order, and the applicant's arguments distinguishing the prior art had to be dealt with.

Why it matters to a reader of this provision

Refusal orders are the point at which many Indian applications end, and appeals against them turn on whether the order can be understood. This judgment fixes a minimum standard of reasoning that Controllers are expected to meet, and gives applicants a clear basis for appeal when an order ignores their submissions. It also restates the inventive step enquiry in a form both examiners and applicants can follow.

Provisions this judgment interprets

Open a provision for the plain-language explanation, the worked example and the forms and deadlines it touches.

Does this judgment affect your matter?

Whether a decision helps or hurts depends entirely on your facts and your claims. A patent professional can tell you which.