Bombay High Court Restores Injunction Protecting Atomberg's Ceiling Fan Design

Dark five-blade ceiling fan under a wooden ceiling

Photo: funeyes / Pixabay

A Division Bench of the Bombay High Court has restored an interim injunction stopping Stove Kraft Limited from making and selling its Pigeon Fan-tastic ceiling fan, after finding that it imitates the registered design of Atomberg Technologies' Renesa Alpha fan. The judgment, by Justices Bharati Dangre and Manjusha Deshpande, was pronounced on 16 October 2026 and uploaded on 22 October 2026.

Background

Atomberg registered its fan design on 1 January 2020 in Class 23-04 (ceiling fans), under registration number 325322-001. According to LiveLaw's report of the judgment, Atomberg said the novelty lay in the overall shape: petal-shaped blades with asymmetric tapering and a slight V-bend, together with the curved body and canopy. A single judge had refused interim relief in April 2026. On appeal, the Bench set that order aside and restored an earlier ad-interim order of July 2025, including the appointment of a Court Receiver to take possession of the disputed fans.

The "eye test"

The core of the ruling is how designs are compared. The Bench held that the test under India's Designs Act, 2000 is a visual one: whether, looking at the two products as a whole, one is substantially the same as or an imitation of the other. Breaking the products into small technical differences is not the right approach. The court gave little weight to the shape of the fan's shaft, which Stove Kraft relied on, because Atomberg had not claimed the shaft as a novel feature in its registration.

The court also noted, according to the report, that Atomberg had used the design commercially since November 2020, that Stove Kraft adopted its fan in February 2025, and that Stove Kraft had not produced prior art showing the same combination of features. It found a case for passing off as well, holding that actual confusion does not need to be proved; a likelihood of confusion is enough. Atomberg's damages claim in the main suit has not yet been decided.

What it means for design owners in Indonesia

Indonesia's Law No. 31 of 2000 on Industrial Designs protects new designs based on their shape, configuration, lines or colours, and an owner can sue in the Commercial Court for infringement. As in India, the protection follows what was registered. This ruling shows why the drawings and the description of novelty in a filing matter: features that were never claimed, like the fan shaft here, are unlikely to carry weight later. Owners of consumer products should also keep dated records of launch and sales, because those supported both the design claim and the passing off claim in Mumbai. We are not aware of an Indonesian court decision applying a test framed in the same "eye test" terms.

Sources

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