Patent licensing disputes under the Patents Act are treated as outside CCI jurisdiction in patent-specific matters.

The Patents Act, 1970 is described as the special and later enactment governing patent licensing disputes, including working of patents, compulsory licensing, revocation, restrictive conditions, reasonable royalty, and alleged anti-competitive conduct by a patentee. The analysis notes that the Competition Act, 2002 generally addresses anti-competitive agreements and dominance, but section 3(5)(i)(b) preserves reasonable conditions needed to protect patent rights and the relevant Competition Act factors overlap with the Controller's patent-specific inquiry. On this basis, patent licensing disputes of this kind are treated as falling within Chapter XVI of the Patents Act, and CCI jurisdiction is excluded in relation to conduct exercised under patent rights.

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Issues: Whether the Competition Commission of India can exercise jurisdiction under the Competition Act, 2002 to inquire into the conduct of a patentee in relation to licensing of patents, including alleged FRAND-related conduct and royalty terms, or whether Chapter XVI of the Patents Act, 1970 is the exclusive field governing such matters.

Analysis: The statutory scheme of the Patents Act, 1970 confers exclusive patent rights subject to the Act and, through Chapter XVI, specifically regulates working of patents, compulsory licensing, revocation, restrictive conditions, reasonable royalty, and conduct said to be anti-competitive in the patent context. The Competition Act, 2002 generally addresses anti-competitive agreements and abuse of dominant position, but section 3(5)(i)(b) preserves reasonable conditions necessary to protect patent rights, and the factors under sections 19, 26, 27 and 28 substantially overlap with the inquiry entrusted to the Controller under Chapter XVI. The relevant subject matter is not competition generally, but alleged abuse by a patentee in exercise of patent rights. On the purpose, policy, and legislative sequence, the Patent Act is the special and later enactment for this field, and the legislative intent is that patent-specific disputes of this kind be dealt with under the Patents Act rather than by the CCI.

Conclusion: The CCI has no jurisdiction to investigate or determine the patentee's conduct in exercise of rights conferred under the Patents Act, 1970, and the impugned CCI proceedings could not be sustained.

Ratio Decidendi: Where a later, patent-specific statutory scheme provides a complete framework for inquiry and relief concerning alleged unreasonable patent licensing conditions and abuse by a patentee, the Competition Act yields to the Patents Act in that field, and CCI jurisdiction is excluded.

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