Second, Philip Morris contended that the IPO had erred in relying on the ENDS Act while assessing patentability. On the issue of non-speaking orders, the court held that the refusals violated principles of natural justice. Significance of the rulingThe ruling is another crucial development in the evolving jurisprudence on the patentability of nicotine and tobacco-related technologies in India. More broadly, it reinforces that section 3(b) must be applied with reference to the specific invention, claims and evidence on record. Generalised policy concerns, regulatory prohibitions or prejudice against a category of substances cannot by themselves justify refusal of patent protection.