Calcutta High Court Says Screen Icons and Digital Layouts Can Be Registered Under Designs Act

In Nec Corporation v. Controller of Patents and Design, the Calcutta High Court has held that screen icons, menus, and digital layouts shown on phones, computers, and other display devices can be registered under the Designs Act, 2000. The ruling is an important step in recognising modern digital product design within Indian intellectual property law.

Justice Ravi Krishan Kapur set aside several orders passed by the Controller of Designs, which had earlier rejected such applications. Those rejections were based on the view that graphical user interfaces, or GUIs, were only software-based features and not designs applied to physical articles.

The case came before the Court through multiple appeals filed by companies including NEC Corporation, Abiomed Inc, and TVS Motor Company. Their applications covered visual features such as dashboard pictograms, display layouts, and other screen-based design elements used in products and devices.

The Controller had argued that these digital features lacked permanence and therefore could not qualify for protection. It was also claimed that GUIs were not “articles” under the Designs Act because they did not have a standalone physical form in the traditional sense.

The High Court rejected this narrow reading of the law. It observed that the Designs Act protects visual features such as shape, pattern, ornament, configuration, and composition of lines or colours. The Court found that GUIs clearly contain these elements through icon design, spacing, colour schemes, arrangement, and layout choices.

The Court also said the expression “article of manufacture” under Section 2(a) is broad and cannot be confined only to physically fixed objects. It noted that such a limited interpretation would leave digital designs outside legal protection, even though they form a key part of modern consumer products.

On the question of industrial process, the Court held that the law uses the word “any,” which must be understood in a broad and evolving manner. According to the Court, displaying a GUI on a screen through a combination of digital and physical processes can fall within the idea of industrial application.

The Court further ruled that permanence is not a legal requirement under the statute. What matters is whether the design is visible when the article is used in its normal or intended manner. A design does not lose protection simply because it appears on a screen when the device is in operation.

It also clarified that a GUI may perform functional tasks, but it can still qualify for registration if it has visual appeal that is not purely dictated by function. The Court added that such protection would not create improper overlap with copyright law.

By remanding the matters for fresh consideration, the judgement opens the door for wider recognition of digital interface design in India. The ruling brings Indian design law closer to present-day technology and may have a major impact on how businesses protect visual innovation in the digital era.