Patent Law – Computer-Related Invention – Section 3(k) – Technical Contribution – Graphic Data Lineage Generation – Rejection on ground of being algorithmic and lacking technical effect – Held: System incorporating diagram generator, metadata querying interface, configuration information sets, and dynamic iterative lineage generation constitutes technical effect and technical contribution – Not excluded under Section 3(k) [Paras 17–54]

Patent Law – Database Management System – Technical Effect – Claim enabling ad-hoc upstream/downstream tracing of data transformations using metadata – Reduction of query response time, avoidance of manual multi-step tracing, and configuration-based autonomous retrieval amount to technical advancement – Invention not mere presentation of information nor simple execution of an algorithm – Technical effect established [Paras 49–54]

Patent Law – Novelty and Inventive Step – Section 2(1)(j) – Prior Art D1 distinguished – D1 disclosed entity-relationship visualisation but did not disclose tracing of data evolution, metadata configuration sets with distinct selection specifications, or iterative querying of metadata management systems – Claimed invention addresses a different technical problem and yields different technical results – Not obvious to PSITA even with common general knowledge – Novelty and inventive step satisfied [Paras 55–61]

Computer Programme Per Se – Technical Effect Test – Indian Position aligned with EPO rather than UK approach – Indian jurisprudence recognises patentability where software-enabled inventions use technical means to solve technical problems – CRI Guidelines 2025 emphasise technical contribution, consistent with precedents such as Lava International and Microsoft decisions – Held: Claimed invention not barred by Section 3(k) [Paras 19–48]

Decision: Appeal allowed – Rejection order dated 13/07/2020 set aside – Patent Application No. 4693/CHENP/2010 to proceed to grant based on last submitted claims – No order as to costs.

Intellectual Property – Trademark Infringement – Device Mark – Word Mark – Invalid Registration – Concealment – Appeal Dismissed – Appellant had valid registration only for device mark containing the word QUANTUM and not for the standalone word mark – Registration certificate for the word mark obtained improperly without applying for it – Appellant failed to disclose this to the court – Held: Concealment of application and affidavit constituted wilful suppression disentitling interim relief under Order XXXIX CPC – Appellant cannot rely on invalid registration for claiming exclusivity [Paras 18.1–18.14, 19.1, 21.2].

Trademark Infringement – Device Mark – Dominant Part Doctrine – Appellant entitled to protection of device mark against similar use of dominant element “QUANTUM” by respondent – Respondents admitted user of marks QUANTUM and QUANTUM DISPLAY since 2015 through affidavit – Goods such as TVs and displays held similar to registered goods under Class 9 – Likelihood of confusion exists – Infringement made out in principle – However, relief denied due to lack of clean hands [Paras 19.2–19.14].

Trademark Law – Passing Off – Lack of Evidence – Though respondents admitted adoption of QUANTUM and QUANTUM DISPLAY marks in affidavit, no evidence of actual use or sale in market produced – Manner of use not established – Goodwill of appellant prior to 2015 not proven – No misrepresentation or deception established – Held: No prima facie case of passing off made out [Paras 20.1–20.6].

Civil Procedure – Interim Relief – Clean Hands Doctrine – Appellant concealed affidavit and registration details which revealed invalidity of word mark registration – Court reiterates that equitable relief like interim injunction not available to a party approaching with unclean hands – Appeal rightly dismissed on this ground [Paras 18.10–18.14, 21.2].

Decision: Appeal dismissed – Appellant disentitled to interim relief due to deliberate concealment of material facts – Though prima facie case of infringement established on basis of device mark, Court declines to interfere due to lack of bona fides – No case of passing off made out – No order as to costs.

Criminal Law – Quashment of FIR – Section 482 CrPC – Cheating and Criminal Breach of Trust – Allegations that petitioners received ₹3.86 crore under subcontract agreement but diverted construction material and failed to complete work – Specific allegations of dishonest intention and misappropriation of funds from inception of contract found in complaint – Petitioners allegedly shifted materials to personal project and retained valuable equipment – Held: Prima facie offences under Sections 406 and 420 IPC made out – FIR not liable to be quashed merely because of existence of arbitration clause or civil nature of dispute – Delay in lodging FIR explained – Limitation under Section 468 CrPC not a bar to investigation of offence punishable with 7 years imprisonment [Paras 2–4, 8–11, 16–21].

Corporate Criminal Liability – Lifting of Corporate Veil – Petitioners being Managing Director and Director accused of personal misuse of company funds and materials – Specific allegations of active involvement in acts of misappropriation – Held: When individuals controlling company are accused of dishonest acts, they cannot seek shelter under corporate veil – Sufficient averments to continue criminal proceedings [Paras 14–15].

Territorial Jurisdiction – Place of Cause of Action – Petitioners contended that no part of offence took place in Hyderabad – Held: Transfer of misappropriated funds occurred in Hyderabad; company offices located in Hyderabad – Investigation can proceed even if jurisdiction questionable – As per Section 156(2) CrPC and Satvinder Kaur judgment, police can investigate offence irrespective of territorial jurisdiction at this stage [Paras 4.6, 28–29].

Civil vs Criminal Remedy – Arbitration Clause – Petitioners argued arbitration clause existed in contract – Held: Arbitration clause does not bar criminal prosecution if allegations make out prima facie offence – Allegations in FIR include dishonest intention and misappropriation from inception, which cannot be resolved merely by arbitration [Paras 4.4, 16, 19].

Power under Section 482 CrPC – Scope – Court reiterated that inherent power must be used sparingly – When FIR discloses cognizable offence and investigation is ongoing, courts should not interfere at threshold stage – Petitioners not entitled to quash FIR when disputed facts require investigation [Paras 20, 27, 30–31].

Decision: Petition dismissed – FIR not quashed – Criminal proceedings to continue – Observations confined to decision on quashment and not to affect merits of investigation or trial [Para 33].

Unlawful Activities (Prevention) Act – Section 43D(5) – Bail – Prima Facie True Test - Appellant, alleged active member of terror syndicate led by Sujit Sinha and Aman Sahu, charged under UAPA, IPC, Arms Act and Explosive Substances Act for orchestrating the 18.12.2020 Tetariyakhad Colliery attack involving indiscriminate firing, arson of four trucks, and injuries to civilians – Recovery of country-made pistol from appellant – FSL report confirmed shells from the crime scene were fired from the appellant’s weapon – Protected witnesses identified the appellant as one of the armed attackers – Court reiterated that under Section 43D(5) UAPA, bail must be denied where accusations are prima facie true – National Investigation Agency v. Zahoor Ahmad Shah Watali (2019) 5 SCC 1 applied [Paras 33–37, 45–57, 69–73].

Bail – UAPA Offences – Delay in Trial – Applicability of Article 21 – Appellant in custody since 07.02.2021 – Trial commenced and witnesses under examination – Court held mere delay not ground for bail in serious terrorist offences; distinguished Union of India v. K.A. Najeeb (2021) 3 SCC 713, as trial had progressed and constitutional violation not established – Gurwinder Singh v. State of Punjab (2024 SCC OnLine SC 109) followed [Paras 64–65, 68].

Bail – Principle of Parity – Distinction Between Co-accused – Co-accused Prabhat Kumar Yadav @ Dimple Yadav granted bail based on long custody and minimal role – Present appellant identified as principal conspirator who directed co-accused Ajay Turi to write threatening pamphlets and participated in arson and firing – Court held parity cannot be mechanically applied; role-specific analysis required – Ramesh Bhavan Rathod v. Vishanbhai Makwana (2021) 6 SCC 230 and Tarun Kumar v. Asst. Director, ED (2023 SCC OnLine SC 1486) relied upon – Held: parity not available [Paras 66–73].

Bail – Restrictive Scope under UAPA – “Bail the Exception, Jail the Rule” – Court reaffirmed that conventional bail principle “bail is the rule, jail is the exception” does not apply under UAPA – Once prima facie satisfaction of involvement exists, bail must be rejected as a rule – Gurwinder Singh v. State of Punjab (supra) and Watali (supra) reaffirmed [Paras 38–44, 53–57].

Result – Appellant failed to show change in circumstances or new grounds – Material on record shows active participation in terrorist act and recovery of incriminating weapons – Trial ongoing – Bail rejected – Appeal dismissed [Paras 63–75].

NDPS Act – Section 21 – Conviction – Appeal – Appellant convicted for possession of commercial quantity of heroin (nearly 6 kg) recovered from bag on motorcycle – Search conducted after informing appellant of right under Section 50 NDPS Act – Recovery in presence of DSP and consent recorded – Samples drawn on spot and sealed – Produced before Magistrate next day – Seals found intact – Held: Recovery not from person but from bag – Hence, Section 50 not applicable – Compliance with Section 52A satisfied – Conviction upheld [Paras 6-12].

Section 50 NDPS Act – Applicability – Heroin recovered from bag carried on motorcycle – Not personal search – Held: As per SC rulings (Pawan Kumar, Ranjan Chadha, Prabhu), Section 50 applies only to personal search – Voluntary consent given and recovery witnessed by DSP – No violation found [Paras 8-9].

Section 52A NDPS Act – Drawing of Samples – Appellant contended that samples not drawn before Magistrate – Held: Samples taken at spot in accordance with Standing Orders – Inventory, samples, and case property presented before Magistrate next day – Seals intact – No prejudice shown – Procedural compliance deemed sufficient – Recent SC judgment in NCB v. Kashif relied on [Paras 10-11].

Independent Witness – Non-joinder – Contention of no public witness during recovery – Held: Ruqa shows attempt was made to join public witnesses but none were available – Prosecution version corroborated by consistent testimony of officials – Not fatal to case [Para 13].

Decision: Appeal dismissed – Conviction and sentence under Section 21 NDPS Act confirmed – No infirmity found in trial court’s findings [Para 14].

Maintenance – Section 144 BNSS – Son’s Independent Obligation to Maintain Aged Mother – Husband’s Support Not a Bar – Alleged Cattle Rearing Unsupported – Son Employed Abroad with Sufficient Means – Maintenance of Rs.5,000 Upheld – Revision Dismissed [Paras 6–9].

Maintenance of Parents – Section 144 BNSS (Sec.125 CrPC) – Independent and Concurrent Obligations – Court held that a mother’s right to seek maintenance from her son under Section 144(1)(d) BNSS is independent of her right to seek it from her husband under Section 144(1)(a) – Obligation of son is not extinguished merely because husband is alive or allegedly maintaining her – Rights under Section 144 are mutually exclusive and co-existent – Family Court rightly rejected claim that husband’s support bars maintenance from son [Paras 6–7].

Social Justice – Liberal Construction of Maintenance Provision – Section 144 BNSS is a measure of social justice intended to protect vulnerable dependents such as destitute wives, children and aged parents – Provision must be interpreted liberally in favour of claimants to achieve welfare objectives of Articles 15(3) and 39 of the Constitution [Para 6].

Allegation of Cattle Rearing by Mother – Unsupported and Unacceptable – Plea that 60-year-old mother is rearing cattle and earning sufficiently was rejected as baseless – Court criticised the moral impropriety of expecting an aged mother to perform physically demanding labour merely to avoid statutory obligation – No evidence produced by son; petitioner did not enter witness box; respondent gave categorical evidence of no income [Para 8].

Son’s Plea of Obligation to Maintain His Own Family – No Defence – Contention that petitioner must maintain his wife and child held untenable – Son cannot evade his legal duty to maintain aged parents on the ground of personal family responsibilities [Para 8].

Sufficient Means – Son Employed in Gulf – Evidence showed petitioner employed abroad with sufficient means; denial of income unsupported by documents; mother’s claim of Rs.2,00,000 per month income not disproved – Finding of sufficient means upheld [Paras 5, 9].

Quantum of Maintenance – Rs.5,000 per Month Reasonable – Considering mother’s needs and son’s earning capacity, Family Court award found reasonable and even modest – Court declined to interfere in revision [Para 9].

Decision – Revision Petition dismissed; maintenance order affirmed [Para 9].

Criminal Law - Sect. 138 Negotiable Instruments – Cheque Dishonour – Acquittal Upheld – Statutory Presumption Rebutted – Complainant’s Financial Capacity Not Proved – Accused Raised Probable Defence – Burden Shifted Back to Complainant – Failure to Establish Legally Enforceable Debt – Trial Court’s Acquittal Not Perverse [Paras 8, 8.1, 11–12].

NI Act – Section 139 Presumption – Rebuttal – Financial Capacity – Once Accused Challenges Capacity, Complainant Must Prove Means – Complainant admitted income of Rs. 3000–4200 p.m., absence of proof of borrowing Rs.50,000 or keeping Rs.1,50,000 at home – No documentary proof of loan – Held, foundational facts not proved; presumption stood rebutted [Paras 8, 11].

Defence Version – Probable Defence – Old Cheque Book – Cheques Allegedly Given to Brother-in-Law in 2000 – Business Closed in 2001 – No Relationship with Complainant – Reply to Statutory Notice Consistent With Defence – Held, defence probable on preponderance of probabilities; burden shifted to complainant [Paras 8.1, 8.3, 11].

Appellate Interference – Acquittal – When Not Warranted – Trial Court’s view reasonable and based on appreciation of evidence – No perversity or illegality – Appeal dismissed and acquittal confirmed [Paras 12–13].

Decision: Appeal dismissed – Acquittal confirmed – Bail bond cancelled [Paras 12–14].

Industrial Disputes Act – Representation through Advocates – Section 36(3)-(4) – Labour Court debarred Management’s counsel – Held: Workman’s own appearance through counsel amounts to implied consent and waiver – Leave of Court also implied as Labour Court permitted filing of Vakalatnama and allowed adjournment – Order debarring advocate set aside [Paras 11–18].

Industrial Adjudication – Representation by Legal Practitioners – Section 36(3) & (4) ID Act – Scope and Requirement of Consent and Leave – Complete bar applies only to conciliation – Before Labour Court, appearance permissible with consent of opposite party and leave of Court – Held: Two-fold requirement of consent and leave reaffirmed – Consent may be express or implied; leave may be express or inferred from conduct of the Court – Legal position reiterated from Paradip Port Trust (1977) and Thyssen Krupp (2023) [Paras 9–10, 14].

Implied Consent – Waiver of Objection – Workman filed preliminary objection under Section 36(3)-(4) but subsequently appeared through counsel on 04.10.2024 – This subsequent conduct constitutes waiver of objection and implied consent – Once a party itself appears through advocate, it cannot deny the other side the same facility – Workman’s later claim that the order-sheet recording appearance through counsel was “erroneous” rejected due to absence of rectification application – Order-sheet is conclusive record of court proceedings [Paras 11–13].

Implied Leave of the Court – Labour Court permitting Management’s counsel to appear and allowing adjournment application dated 12.11.2024 amounts to implied leave – Consideration and allowance of application filed by advocate shows Court’s permission – Subsequent attempt by workman to retract not sustainable [Paras 16–17].

Precedents – Paradip Port Trust v. Their Workmen (1977) 2 SCC 339 – Consent and leave are mandatory – Section 36(4) cannot be read as disjunctive – Industrial Disputes Act prevails over Advocates Act as special legislation – Reaffirmed – Thyssen Krupp Industries India Pvt. Ltd. v. Suresh Maruti Chougule (2023 SCC OnLine SC 1707) applied – Patna HC in M/s Key’s Brake Hoses (1999) and Bombay HC in T.K. Varghese (2001) followed on implied consent and unjustified refusal of consent [Paras 14–15].

Judicial Record – Sanctity of Order Sheets – Courts’ orders are conclusive of proceedings – Respondent cannot discredit order-sheet entries without seeking formal rectification – Mere assertion in affidavit insufficient [Para 13].

Decision – Labour Court’s order dated 27.02.2025 debaring advocate unsustainable in law and on facts – Implied consent and implied leave established – Order set aside – Writ petition allowed – Labour Court directed to apprise workman of his right to legal aid and proceed expeditiously [Paras 18–20].

Criminal Law – Rash and Negligent Driving – Identity of Accused Not Established – Accused acquitted by Trial Court for offences under Sections 279 and 337 IPC and Sections 181 and 196 of MV Act – Prosecution failed to conduct Test Identification Parade – Witnesses identified accused for the first time in Court after long lapse of time and in absence of prior familiarity – Held: Dock identification without TIP in such circumstances is highly unreliable and cannot sustain conviction – Acquittal upheld [Paras 6, 14, 16, 19, 20, 25].

Criminal Procedure – Appeal Against Acquittal – Scope of Interference – Appellate court can interfere only if judgment of acquittal is perverse or based on misreading of evidence – Where two views are possible, appellate court must defer to trial court – Held: Trial court’s view was reasonable and based on evidence; High Court refused to substitute alternative view in absence of compelling reasons [Paras 12, 13, 25].

Witness Testimony – Identification in Court – No Prior TIP – Eyewitnesses claimed to identify accused only during trial – No prior identification during investigation – Held: Identification for the first time in Court without prior TIP is weak and inherently suspect – Particularly when visibility was poor, incident occurred at night, and accused was a stranger – Testimony held unreliable [Paras 16, 17, 19, 24].

Investigative Lapses – No Explanation How Accused Was Identified – IO failed to explain how the accused was linked to the incident – No chain of evidence or identification process disclosed – Held: Investigation lacked procedural safeguards; raises doubt about correctness of prosecution case – Acquittal justified [Paras 14, 15].

Decision: Appeal dismissed – Trial Court’s judgment of acquittal affirmed – No error or perversity found – Accused entitled to benefit of doubt – Directed to furnish bond under Section 437-A CrPC / Section 481 BNSS for appearance before the Supreme Court in case of further appeal.