Madras High Court rulingOn 24 April 2025, the Madras High Court ruled on this issue in Annikki v Assistant Controller of Patents and Designs ((T)CMA(PT) 70 of 2023). Accordingly, the court held that deriving a Section 3(d) objection by piecing together elements from distinct prior art references was legally unsustainable. While this judgment offers valuable clarity on the patentability of process claims under Indian law, it stands in contrast to an earlier approach adopted by the Delhi High Court. It further clarified that the expression “known process” within Section 3(d) includes multiple known processes. Therefore, in its March 2023 ruling, the court opined that the scope of patentability of process claims is narrower than product claims.