In Brief
Cryogas Equipment challenged orders by the Commercial Court and High Court of Gujarat in a copyright infringement suit filed by Inox India Limited. The core dispute concerned whether proprietary engineering drawings for cryogenic storage tanks qualified for protection under the Copyright Act, 1957 or fell within the Designs Act, 2000, thereby losing copyright protection after 50 industrial reproductions. The Supreme Court upheld the High Court's rejection of the preliminary dismissal application, emphasizing that determining whether a work is an "artistic work" or a "design" requires detailed trial-level inquiry. The Court formulated a two-pronged test: first, assess if the work is a pure artistic work or a design derived from one; second, if not copyrightable, apply the "functional utility" test under the Designs Act. The case was remanded to the Commercial Court for trial within one year.
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