Delhi High Court Upholds Injunction Barring Canva's 'Present and Record' Feature In India

A Division Bench of Justice C. Hari Shankar and Justice Om Prakash Shukla pronounced the judgment on January 28, 2026, dismissing Canva's appeal and holding that no case was made out for appellate interference with the interim relief granted by the Single Judge.

Holding that the process of claim construction and comparison had been undertaken by the Single Judge in accordance with settled principles of patent law, the Court observed that “a careful reading of the impugned judgment reveals that the learned Single Judge has effectively construed the four disputed claims of the Suit Patent and has undertaken a detailed claim mapping exercise. The learned Single Judge has explicitly observed that claims of the patent specification are required to be compared with the features of the Defendant's product.”

The dispute arose from a patent infringement suit instituted by RxPrism, a Bengaluru-based technology startup engaged in providing digital tools for social selling and digital customer engagement. RxPrism is the proprietor of the patent titled “A system and a method for creating and sharing interactive content rapidly anywhere and anytime.”

RxPrism alleged that Canva's “Present and Record” feature infringes its patented invention by enabling users to create presentations with picture-in-picture video overlays, interactive call-to-action elements and post-creation editing capabilities.

In July 2023, a Single Judge of the Delhi High Court found that RxPrism had established a prima facie case of infringement and granted an interim injunction restraining Canva from making the impugned feature available in India during the pendency of the suit. The Court had also directed Canva to deposit ₹50 lakh as security towards RxPrism's claims for past use of the feature in India.

Aggrieved by the grant of interim relief, Canva filed an appeal submitting that the Single Judge had misconstrued the essential claims of the patent, undertaken an impermissible overall comparison, and wrongly applied the doctrine of equivalents. It also argued that its feature lacked several essential elements of the patented invention, including the absence of what it described as an independent 'sandwiched' interactive layer

Opposing the appeal, RxPrism submitted that the Single Judge had undertaken a detailed claim-to-product mapping and correctly applied settled principles of patent infringement at the prima facie stage. It was argued that minor variations in implementation could not defeat a finding of infringement where the core inventive concept had been adopted in substance.

Upholding the impugned order, the Division Bench held that an appeal against an interlocutory injunction is an appeal on principle and that appellate interference is warranted only where the discretion exercised by the court of first instance is shown to be contrary to settled law.

On the issue of infringement, the Bench agreed with the Single Judge that the differences highlighted by Canva were insignificant and did not detract from the presence of the essential elements of the patented invention.

Noting that RxPrism's patent contemplates a “configuration interface” enabling the placement of call-to-action button at a specific position within the interactive content, the Court observed that, “The Defendant's (Canva's) interface performs precisely this function. Merely labelling it as a “formatting option” is a semantic manoeuvre that does not alter its substantive function. The Defendant's product, therefore, performs the same function in substantially the same way to achieve the same result.”

Holding that the Single Judge had correctly focused on a claim-to-product comparison, the Court observed, “We therefore find no error of principle in the approach adopted by the learned Single Judge either in claim mapping or in comparing the prior art with the claims of the Suit Patent.”

The Court also found no infirmity in the direction requiring Canva to deposit ₹50 lakh, holding that the measure was protective and provisional in nature, intended to safeguard RxPrism's interest.

Accordingly, the Court dismissed the appeal, clarifying that its observations were prima facie in nature and would not affect the merits of the pending suit.

For Appellants: Advocates Saikrishna Rajagopal, Sneha Jain, Victor Vaibhav Tandon, Shruti Jain and Ayush Saxena

For Respondents: Senior Advocate Swathi Sukumar with Advocates Kriti Ranjan, Vishal, Ritik Raghuvanshi and Abhishek Ranjan