The Delhi High Court in Dong Yang PC, Inc. v. Controller of Patents & Designs [C.A. (COMM.IPD-PAT) 60/2024], on 1 July 2025, considered an appeal under Section 117A against a Section 15 refusal of 2554/DEL/2013 (“Vertical Rotary Parking System”). A pre-grant opposition filed against the application had cited documents D-1 to D-4, and shortly before the hearing, an additional prior art document, D-5, was introduced. In response, the applicant filed Form-13 seeking to amend the application in reliance on Sections 57-59. The Controller, however, rejected the proposed amendments and refused the application on the ground that the claimed invention lacked inventive step under Section 2(1)(ja), describing the claimed features as no more than a “mere workshop modification.”
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