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Introduction
The Delhi High Court’s ruling in Canva Pty Ltd v. RxPrism Health Systems1 represents a sophisticated evolution in Indian patent jurisprudence, marking a definitive shift in how the judiciary evaluates software-related inventions. By upholding an interim injunction against Canva’s ‘Present and Record’ feature, the Division Bench has signaled that the spirit of an invention’s substantive architectural core will be protected against even the most polished “colorable variations.” This judgment does more than settle a dispute between two tech entities; it provides a modern roadmap for the Doctrine of Equivalents in an era where software processes are increasingly complex and abstract.
At the heart of this issue was RxPrism’s Indian Patent No. 360726, which covers a system for creating interactive multimedia presentations. Canva sought to overturn a previous injunction by arguing that its technology lacked the specific structural “layers” described in the patent and functioned without certain haptic features like the manual movability of video overlays. However, the court’s analysis moved swiftly past these literalist defenses, leaning instead into the principle of purposive interpretation. By reading the patent through the eyes of a Person of Ordinary Skill in the Art (POSITA), the court determined that the inventive concept was not rooted in rigid structural compartmentalisation but in the functional architecture that allowed for synchronized, layered media delivery.
The court anchored its infringement analysis in the two-stage test from F. Hoffmann-La Roche v. Cipla2, which mandates first construing the patent claims and then comparing that construction to the infringing product. To ensure this construction was not too narrow, the Bench invoked Bishwanath Prasad Radhey Shyam v. Hindustan Metal Industries3, emphasizing that specifications must be read as a whole. This holistic approach ensured that Canva could not escape liability by pointing to minor structural deviations when the functional heart of the technology remained the same.
The most significant legal contribution of this judgment is the nuanced distinction it draws between product and process patents. While previous Indian case law, such as Sotefin SA v. Indraprashtha Cancer Society4, relied on the “triple test” evaluating whether a product performs the same function, in the same way, to achieve the same result, this court recognized that software is often better analyzed through the Essential Element Test. Drawing from FMC Corporation v. Natco Pharma Ltd5, the court focused on identifying the essential steps of RxPrism’s method and comparing how Canva’s software orchestrated those same stages. This approach acknowledges that in the digital realm, the “way” a result is achieved is often found in the logic flow and architectural hierarchy rather than in physical components.
This focus on substance over form allowed the court to dismiss Canva’s “third layer” argument as a semantic distraction. The court observed that an infringer cannot evade liability by simply renaming a “configuration interface” as a “formatting option” or by merging two technical layers into one if the underlying functional result remains identical. By citing the long-standing precedent of Raj Parkash v. Mangat Ram Chowdhury6, the Bench reaffirmed that minor or insubstantial changes cannot be used to camouflage the appropriation of a patented idea. The court essentially ruled that if the “heart” of the invention is taken, the “skin” used to cover it be it different terminology or minor UI tweaks is irrelevant to the finding of infringement.
The judgment also provides critical clarity on what constitutes “prior art” in the software space. Canva’s attempt to use Microsoft PowerPoint 2016 as a defense was rebuffed because the court identified a substantive technical advancement in RxPrism’s work. While PowerPoint operated on a traditional, sequential slide-by-slide recording basis, the suit patent enabled a persistent, synchronized video overlay that remained seamless across transitions. This distinction reinforces the idea that technical progress in software is often found in the “seamlessness” and “persistence” of data across a user session, qualities that constitute a genuine technical contribution over existing tools.
The court addressed the standard for appellate interference. Citing Wander Ltd. v. Antox India P. Ltd.7, and the recent Ramakant Ambalal Choksi v. Harish Ambalal Choksi8, the Bench noted that it would only intervene if the trial court’s decision was “perverse” or “arbitrary.” Finding the original analysis to be grounded in evidence, the court chose to respect the lower court’s discretion.
Ultimately, the Canva v. RxPrism decision serves as a robust shield for innovators, particularly startups whose value lies in unique architectural logic rather than massive hardware footprints. It aligns Indian law with international standards seen in the United Kingdom and the United States, emphasizing that patent protection must be broad enough to prevent formalistic circumvention but precise enough to honor the specific inventive step. For the broader tech industry, the message is clear: the Indian judiciary will look through the code and the interface to find the inventive soul of a product, ensuring that the law protects the “why” and “how” of innovation as much as the “what.”
Conclusion
The Canva v. RxPrism judgment stands as a landmark in the digital age, signaling that the Indian judiciary will not be bound by the literal shackles of patent claims when faced with sophisticated technological mimicry. By prioritising the Essential Element Test, the Delhi High Court has bridged the gap between traditional patent law and the fluid reality of software architecture. This decision ensures that the value of a patent lies in its substantive technical contribution, its “architectural soul” rather than its incidental implementation.
This ruling effectively warns that changes in terminology or minor tweaks in user interface will not suffice to bypass the core inventive concept of a patent. For global tech giants and local startups alike, the message is unmistakable: Indian patent law has matured into a regime that values the integrity of innovation over the art of circumvention. By reinforcing the purposive interpretation doctrine, the court has ensured that the Indian legal framework remains a robust and intellectually rigorous guardian of intellectual property in an increasingly complex digital world.
Citations
Expositor(s): Adv. Archana Shukla, Riya Raksha (Intern), Aditi Singh (Intern)
