Delhi High Court Stays Over ₹20 Crore Decrees In Favour Of Philips In DVD Patent Dispute

The Delhi High Court on Monday stayed the execution of money decrees worth over Rs 20 crore passed in favour of Koninklijke Philips N.V., the Netherlands-based electronics company widely known as Philips. The stay is subject to the judgment debtors furnishing unconditional and irrevocable bank guarantees covering the principal amounts of damages.

A Division Bench of Justice C Hari Shankar and Justice Om Prakash Shukla said it found no fault with the Single Judge's conclusions on patent infringement, the validity of the patent, or the determination of liability leading to the award of damages.

It repeated that money decrees are normally not stayed in appeal. The stay, it clarified, was granted only because the damages figure itself needed closer scrutiny, not because the findings on liability were in doubt.

The dispute concerns suits filed by Philips alleging infringement of its patent titled “Method of Converting Information Words to a Modulated Signal,” a technology used in DVD manufacturing and replication.

During the pendency of the suits, the patent expired by efflux of time, rendering the relief of injunction infructuous. Consequently, the Single Judge awarded damages of Rs 6.22 crore, Rs 1.61 crore and Rs 12.43 crore respectively in the connected matters, along with interest at the rate of 12% per annum from the date of filing of the suits and additional damages of Rs 1 crore in each case.

Aggrieved by the judgment, Behl and others filed appeals along with applications seeking stay of execution. While deciding the stay applications, the Division Bench examined the principles governing the stay of execution of money decrees under the Code of Civil Procedure, in light of the Supreme Court's ruling in Lifestyle Equities C.V. v. Amazon Technologies Inc.

The Court reiterated that money decrees are ordinarily not to be stayed, except in exceptional circumstances. The bench noted that the Single Judge's findings on infringement, validity of the suit patent, determination of fair and reasonable royalty and the number of stampers supplied to Behl and others did not suffer from patent illegality or perversity.

“In any event, it cannot be treated to be “egregiously perverse”, “ridden with patent illegality” or “facially untenable” and cannot, therefore, constitute a basis to stay the execution of the impugned judgment and decree, in view of the enunciation of the law in para 82 of Lifestyle Equities,” the Court observed.

However, the Bench found prima facie merit in the challenge to the computation of damages, observing that the assumptions regarding the number of DVDs replicated per stamper and the total number of DVDs manufactured were based on presumptions unsupported by evidence.

“The learned Single Judge has proceeded on a presumption that 10,000 DVDs could be replicated from one stamper. No basis for this figure is forthcoming on the record. The figure is, therefore, entirely presumptuous in nature. It is well settled that damages cannot be fastened on a litigant on the basis of mere presumption,” the Court said.

The court accordingly held that directing deposit of the entire decretal amount at this stage would not be justified. At the same time, it declined to grant a blanket stay on judgment and decree, noting that the findings on infringement and patent validity had not been disturbed.

Consequently, the court dispensed with the requirement of depositing the decretal amount and directed Behl and others to furnish unconditional and irrevocable bank guarantees, with an auto-renewal facility, drawn on a nationalised bank, covering the principal amount of damages awarded in each case.

The court ordered that upon furnishing of the bank guarantees, execution of the judgment and decree shall remain stayed till further orders, clarifying that the stay is subject to the outcome of the appeals. The appeals have been directed to be listed for further hearing on January 15, 2026.