Bombay High Court Finds No Novelty In Atomberg Fan Design, Refuses Interim Relief Against Stove Kraft

The Bombay High Court has recently declined to continue interim protection granted earlier to Atomberg Technologies Pvt. Ltd. in its design infringement suit against Stove Kraft Limited's “Pigeon” brand, finding that the rival ceiling fan is visually distinct and that the plaintiff's design does not show any real novelty beyond that of a standard ceiling fan.

Justice Gauri Godse was deciding an application seeking to confirm an earlier ad-interim injunction passed on July 24, 2025, which had restrained Stove Kraft from manufacturing and selling the impugned fan. A Court Receiver had also been appointed at that stage to seize the products.

Atomberg's case rested on its registered design for the “Renesa Alpha” ceiling fan. The company said it had developed the design in late 2019, secured registration from January 1, 2020, and launched the product in November that year.

According to it, the fan's look, including the blade shape, shank profile, and overall form, was original, and its commercial success led to multiple variants under the “Renesa” line.

It accused Stove Kraft of copying this design in its “Pigeon Fan-tastic BLDC Ceiling Fan,” alleging that the rival product reproduced the same visual features and overall appearance.

Stove Kraft pushed back, saying the comparison itself was flawed. The company argued that Atomberg had not matched the impugned fan against the registered design, but against newer models introduced later. It also questioned whether the design was new at all, pointing to similarities with existing fans in the market. On the issue of goodwill, it highlighted that only 157 units under the specific registered design had been sold since 2020.

The court found merit in this objection. It noted that the plaintiff's comparison relied on images of subsequent models rather than the registered design, which made the exercise misleading.

Looking at the design itself, the Court was not persuaded that it brought anything new to the table. Elements such as blades, canopy, shank and motor housing are common to any ceiling fan, it said, and cannot be treated as novel in themselves.

“The overall basic functional appearance of a ceiling fan cannot be compared to identify similarities for the purpose of alleging infringement of a registered design in the absence of any novelty,” the court observed, adding that only features that stand out from the usual design could qualify for protection.

When the two products were viewed side by side, the differences were apparent. The court pointed to variations in blade design, motor housing, shank profile, rivet placement, and canopy. The features that Atomberg claimed as distinctive, including the so-called “Z”-shaped shank, were not found in Stove Kraft's fan.

“When both the fan designs are seen as a whole, the impugned fan is substantially different from the suit fan,” the court said.

On the passing off claim, the court said Atomberg had not shown that the design had acquired distinctiveness in the market. Mere similarity would not suffice. There had to be something more to link the product to the plaintiff in the mind of a buyer. The reliance on a chartered accountant's certificate covering multiple models did not establish goodwill in the specific registered design, it added.

With no prima facie case made out and no balance of convenience in its favour, the court declined to grant interim relief. The earlier order appointing the Court Receiver was set aside, and the seized goods were directed to be released.

For Applicant/Plaintiff: Dr. Veerendra Tulzapurkar, Senior Advocate a/w. Mr. Hiren Kamod, Mr. Vaibhav Keni, Ms. Neha Iyer, Ms.Proutima Ray, and Mr. Vishwajeet Jadhav i/b. Legasis Partners

For Defendant/Respondent: Mr. Venkatesh Dhond, Senior Advocate a/w. Mr. Akshay Patil, Mr. Akshay Kamble, Ms. Neha Patil, Ms. Trupti Poojary, Mr. Prateek Pansare a/w. Ms. Reshma Rajgopalan i/b. Vivaka Partners