Facts Of The Case:
Atomberg Technologies launched its “Atomberg Intellon” water purifier on June 20, 2025. Shortly after, its competitor, Eureka Forbes Limited, allegedly made oral threats to Atomberg’s distributors, claiming patent infringement and threatening legal action. In response, Atomberg filed a suit for “groundless threats of infringement” under Section 106 of the Patents Act, 1970, at the Bombay High Court on July 1, 2025. Separately, Eureka Forbes, upon discovering the product, purchased it online and had it delivered to Delhi. After a technical analysis, it alleged patent infringement and subsequently filed its own suit for infringement under Section 104 of the Act at the Delhi High Court on July 7, 2025. Both parties then filed cross-transfer petitions before the Supreme Court. Atomberg sought to move the Delhi suit to Bombay, arguing its suit was filed first and both companies were based in Mumbai. Eureka Forbes sought to bring the Bombay suit to Delhi, contending the cause of action for infringement arose there due to the product’s delivery and that its suit addressed the substantive issue of infringement. The Supreme Court was tasked with deciding which court should adjudicate the intertwined disputes.
Procedural History:
The litigation commenced when Atomberg Technologies filed a suit for groundless threats of patent infringement (Bombay Suit) before the Bombay High Court on July 1, 2025. Subsequently, Eureka Forbes Limited filed a suit for patent infringement (Delhi Suit) before the Delhi High Court on July 7, 2025. Following these parallel filings, Atomberg filed Transfer Petition (Civil) No. 1983 of 2025 before the Supreme Court, seeking to transfer the Delhi Suit to Bombay. In response, Eureka Forbes filed Transfer Petition (Civil) No. 2174 of 2025, seeking the transfer of the Bombay Suit to Delhi. The Supreme Court, exercising its jurisdiction under Section 25 of the Code of Civil Procedure, heard both transfer petitions together and, by its judgment dated October 17, 2025, allowed Atomberg’s petition, thereby transferring the Delhi Suit to the Bombay High Court to be tried jointly with the pending Bombay Suit, and consequently dismissed Eureka Forbes’s transfer petition.
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Court Observation:
The Supreme Court observed that the suit for groundless threats filed by Atomberg under Section 106 of the Patents Act was instituted prior in time to the infringement suit filed by Eureka Forbes. It noted that while both suits represented independent causes of action, the legal and factual issues in the two proceedings were substantially overlapping, centering on the same patent and product. The Court found that trying these interconnected matters in two different High Courts would lead to duplication of evidence, risk of conflicting judgments, and wastage of judicial resources. It further observed that the invocation of jurisdiction by Eureka Forbes in Delhi, based solely on an online purchase and delivery, did not outweigh the considerations of procedural efficiency and the prejudice caused by parallel litigation, especially when both parties had their registered offices in Mumbai. Emphasizing the need to avoid multiplicity of proceedings, the Court held that consolidating the cases before the Bombay High Court, where the first suit was filed, was in the interest of justice and judicial economy.
Final Decision & Judgement:
The Supreme Court allowed Transfer Petition (Civil) No. 1983 of 2025 filed by Atomberg Technologies. It directed the transfer of the patent infringement suit (CS (COMM) No. 663 of 2025) filed by Eureka Forbes Limited and pending before the Delhi High Court to the Bombay High Court. The transferred suit was ordered to be tried jointly with the previously instituted suit for groundless threats (Commercial IP (L) No. 19837 of 2025) filed by Atomberg, which was already pending before the Bombay High Court. Consequently, the Court dismissed the cross-transfer petition (Transfer Petition (Civil) No. 2174 of 2025) filed by Eureka Forbes. The Court also directed that any pending injunction applications in the suit be taken up and disposed of expeditiously. The judgment was delivered on October 17, 2025, by the bench comprising Justices Pamidighantam Sri Narasimha and Atul S. Chandurkar.
Case Details:
Case Title: Atomberg Technologies Private Ltd. v. Eureka Forbes Limited & Anr. Citation: 2025 INSC 1253 Civil Appeal No.: Transfer Petition (C) No(s). 1983 of 2025 (along with Transfer Petition (C) No. 2174 of 2025) Date of Judgement: October 17, 2025 Judges/Justices Name: Justice Pamidighantam Sri Narasimha and Justice Atul S. Chandurkar