Monsanto Technology LLC & Ors v. Nuziveedu Seeds Ltd & Ors

Core point: The case turns on Section 3(j) of the Patents Act and on how courts should decide complex patent questions. Monsanto licensed its Bt cotton technology to Nuziveedu. A payment dispute led to litigation. The Delhi High Court’s Division Bench treated validity issues in a summary way and revoked the patent. The Supreme Court said: do not shortcut science-heavy questions—hold a full trial with evidence and experts.

• Did the Petitioner consent to a summary decision on patent validity?
• Was the Division Bench right to invalidate the patent without a full trial?

• Patents Act, 1970 – Section 3(j): Plants and animals, including seeds, varieties and species, are not patentable.
• Contract Law – Contractual Obligations: Parties are bound by agreed terms; failure to pay can justify termination, subject to law and equity.

Held: The Supreme Court agreed with the Petitioner on process. There was no basis to treat their stance as consent to summary adjudication. The DB’s approach was premature. Technical questions should go to trial with scientific evidence and expert input. The Single Judge’s approach—keeping use tied to payment of trait fee—was the correct interim path.

Ratio: Courts must not summarily decide patent validity where complex scientific facts are in dispute. Section 3(j) questions, biotech claims, and gene/trait integration require evidence and expert testimony at trial. Interim relief should balance rights and payments under the contract.

• Sets a process benchmark for biotech patents: trial first, decision next.
• Clarifies that licensing & payments can be protected through interim orders.
• Helps align IP and agriculture policy under Section 3(j).

Mnemonic: S-E-E-D — Summary? No (trial first); Evidence and experts; Exclusion in 3(j); Due payments continue.

1. Spot Section 3(j) and the biotech angle.
2. Explain why science-heavy facts need expert proof.
3. Decide only after trial; keep interim balance on fees.

Issue: Can the patent be summarily invalidated, and did Monsanto consent to that path?

Rule: Section 3(j) bars patents on plants/seeds; validity must be tested with evidence where facts are technical.

Application: The DB bypassed trial despite complex gene/trait questions. That needed expert testimony.

Conclusion: No summary invalidation; proceed to trial. Interim: use allowed with trait fee payment.

Section 3(j)

A bar on patenting plants, seeds, and biological varieties in India.

Trait Value

Contractual fee paid for using licensed technology embedded in seeds.

Summary Adjudication

Deciding a dispute without full trial; risky for science-heavy patent issues.