Tootal Broadhurst Lee Company Ltd v Ahamed and Sons Ltd (Consolidated Civil Case Nos. 281 and 350 of 1950 (Mombasa))
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The court held that certificates of registration from the Patent Office are not admissible under sections 74-77 of the Evidence Act as they are not documents open to public inspection and the certificate was not written at the foot of the copy as required. However, the documents are admissible under section 82 as they would be admissible in England under section 24 of the Registered Designs Act 1949. The court found infringement established where the defendant sold fabric bearing designs identical to the plaintiff's registered designs. The plaintiffs are entitled to an account of profits as equitable relief, as courts exercise this remedy in equity for design infringement cases, notwithstanding the claim for damages in the plaint.
Outcome
Plaintiffs granted injunction, delivery up of infringing fabrics, and account of profits
Facts
The plaintiffs claimed infringement of registered designs Nos. 413032 and 413422. In November 1948, Khandwalla and Company (affiliated to the defendant company) purchased three lengths of cotton fabric printed with the plaintiffs' registered designs from the plaintiffs through their agents. Subsequently in 1950, the defendants were found to have imported and sold printed cotton fabric manufactured in Japan bearing designs identical to those of the plaintiffs. The designs were identical in every respect, differing only in fabric quality and colour. The plaintiffs sought to prove their ownership of the registered designs through documents bearing the seal of the Patent Office of Great Britain, purporting to be copies of the certificates of registration together with certificates signed by an officer authorized by the Board of Trade under the Registered Designs Act 1949.
Issues
- Whether the plaintiffs are the registered proprietors of the designs in question based on documents bearing the seal of the Patent Office of Great Britain.
- Whether the documents produced are admissible as certified copies of public documents under sections 74-77 of the Evidence Act.
- Whether the documents are admissible under section 82 of the Evidence Act.
- Whether there has been infringement of the registered designs by the defendants.
- Whether the plaintiffs are entitled to an account of profits as equitable relief despite claiming damages in the plaint.
Orders
- Judgment for the plaintiffs.
- Injunction granted restraining the defendants from infringing the registered designs.
- Defendants to deliver up the offending fabrics.
- Defendants to account for profits realized on the sale of the infringing fabrics.
- Payment of such profits to the plaintiffs by way of damages for the infringements.
- Costs of the suits awarded to the plaintiffs.
Rules and key headnotes
Legislation cited (10)
- Evidence Act s.74
- Evidence Act s.76
- Evidence Act s.77
- Evidence Act s.82
- Patents and Designs Acts 1907-46
- Registered Designs Act 1949 s.18
- Registered Designs Act 1949 s.24
- Registered Designs Act 1949 s.48(2)
- Patents and Designs Act 1907 s.51
- Patents and Designs Act 1907 s.62(3)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.