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42. The Court now proceeds to deal with the four grounds seeking revocation.

Objection under Section 64(1)(e) of the Patents Act

43. Section 64(1)(e) provides that a patent is liable to be revoked if the invention so far as claimed in any claim of the complete specification is not new, having regard to what was publicly known or publicly used in India before the priority date of the claim or what was published in India or elsewhere in any of the documents mentioned in Section 13. The test is whether one prior art discloses each element of the patented claim either explicitly or implicitly.

84. This statutory requirement is further enforced through revocation proceedings under the Patents Act. Section 64(1)(f) provides that a patent is liable to be revoked if the claimed invention is obvious or does not involve an inventive step, having regard to what was publicly known or publicly used in India before the priority date. The term "obvious" must be interpreted in its plain and ordinary sense; hence, something that is obvious cannot involve complexity.

110. In light of the foregoing, the Defendant has failed to establish that the Suit Patent lacks an inventive step under Section 64(1)(f) of the Patents Act.

Objection under Section 64(1)(h) and (i) of the Patents Act

111. Under Section 64(1)(h), a patent may be revoked if the complete specification does not sufficiently and fairly describe the invention and the method by which it is to be performed, in a manner that enables a PSA to work the invention. Section 64(1)(i) is a distinct ground for revocation but addresses related concerned under Section 64(1)(h). It provides that a patent may be revoked if the scope of any claim is not sufficiently and clearly defined or if any claim of the complete specification is not fairly based on the matter disclosed in the specification.

126. Accordingly, the objections as to insufficiency of disclosure and lack of fair basis under Sections 64(1)(h) and 64(1)(i) respectively, are rejected.

Examination of Section 64(1)(m) of the Patents Act

127. Section 64(1)(m) of the Patents Act provides for revocation of a patent if the applicant has failed to disclose information to the Controller required by Section 8, or has furnished information which in any material particular, was false to his knowledge. This provision sets a high threshold: