The Delhi High Court’s Division Bench has now pronounced its decision in Canva Pty Ltd & Ors v. RxPrism Health Systems Pvt Ltd & Anr, a significant moment for patent enforcement in the Indian SaaS and tech ecosystem, it is a wake-up call for both SaaS startups and IP practitioners navigating India’s evolving software-patent landscape.
RxPrism, holder of Indian Patent IN 360726 for a system and method for creating and sharing interactive content through a layered architecture (background media, PiP overlay, and a CTA or interaction layer), had earlier secured an interim injunction from the Single Judge against Canva’s “Present & Record” feature. Canva challenged this order in appeal.
The Division Bench has:
- Dismissed Canva’s appeal
- Upheld the finding of a strong prima facie case of infringement
- Maintained the interim injunction restraining Canva from making the “Present & Record” feature available in India
- Sustained the direction to deposit Rs. 50 lakhs as security for past use, along with costs in favour of RxPrism
The Court analysis in detailed technical claim construction, examined prior art, patented methods and expert evidence, and reiterated that even limited infringing use can distort market expectations and licensing opportunities. In other words, low usage numbers do not dilute the patentee’s right to effective interim protection. This signals a maturing judicial approach where backend architecture, data flow, and functional equivalence are central to infringement assessment.
Most importantly, the ruling underscores that software-enabled inventions are enforceable in India when tied to demonstrable technical effects, and that Indian courts are prepared to engage with the complexity of modern digital systems.
It will be interesting to see how this order shapes the way global SaaS companies localise and roll out features for India in an active patent landscape where enforcement is increasingly real.
[Canva PTY Ltd. & Ors. V. RxPrism Health Systems Pvt. Ltd. & Anr. – FAO(OS) (COMM) 211/2023, CM APPLs. 49322/2023, 49325/2023, 63761/2023 & 63762/2023]