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Issues Involved:
1. Whether the patent involved any inventive step or novelty. 2. Whether the method of holding an article by the pressure of a pointed tailstock constituted the novelty of the invention. 3. Whether the invention was a manner of new manufacture or improvement. 4. Whether the failure to examine the alleged inventor, Purshottam Dass, adversely affected the plaintiff's case. 5. Whether the concurrent findings of utility by the lower courts should sustain the patent. Detailed Analysis: 1. Whether the patent involved any inventive step or novelty: The trial court found that the patent did not involve any inventive step, as the method of manufacturing utensils using a lathe with a headstock, adapter, and tailstock had been known and used in the commercial world for decades before the plaintiff's patent. The court concluded that the changes introduced by the patentee were minor and did not involve any novelty. The appellate bench, however, concluded that the method of mounting patented by the appellant did involve an inventive step and was a manner of new manufacture and improvement. The Supreme Court, after reviewing the evidence, sided with the trial court, finding that the patented machine was merely an application of an old invention with a slight change in the mode of application, which did not qualify as an inventive step. 2. Whether the method of holding an article by the pressure of a pointed tailstock constituted the novelty of the invention: The appellate bench held that the novelty and invention of the patent lay in the method of holding an article by the pressure of a pointed tailstock, which was neither used nor known. However, the Supreme Court found this conclusion inconsistent with the appellate bench's own findings that lathes with headstocks and tailstocks had been well known for a long time. The Supreme Court noted that the specification and claims of the patent did not assert novelty for the pointed tailstock, and the patentee's representative admitted that such tailstocks were already in use. 3. Whether the invention was a manner of new manufacture or improvement: The trial court found that the patented machine was not a manner of new manufacture or improvement, as it did not involve any novelty or inventive step. The Supreme Court agreed, stating that the patented machine was a normal development of an existing manner of manufacture and did not produce a new or improved result. The court emphasized that the combination of old known integers must produce a new result or a better or cheaper article to qualify for a patent, which was not the case here. 4. Whether the failure to examine the alleged inventor, Purshottam Dass, adversely affected the plaintiff's case: The trial court noted that Purshottam Dass, the alleged inventor, did not appear in the witness-box to explain the novelty or inventive step of the patented method. The court inferred that his absence adversely affected the plaintiff's case. The Supreme Court concurred, stating that the failure to examine Purshottam Dass, who was a partner of the patentee firm and the best-informed person about the invention, gave rise to an inference adverse to the plaintiff. 5. Whether the concurrent findings of utility by the lower courts should sustain the patent: The Supreme Court rejected the argument that the concurrent findings of utility by the lower courts should sustain the patent. The court emphasized that the crucial test of the validity of a patent is whether it involves novelty and an inventive step, not just utility. Since the patent failed the test of novelty and inventive step, it was invalid and liable to be revoked. Conclusion: The Supreme Court allowed the appeals, set aside the judgment of the appellate bench, and restored the trial court's judgment, which dismissed the plaintiff's suit and revoked the patent. The court held that the patented machine was neither a manner of new manufacture nor a novel improvement and did not involve any inventive step. The parties were left to bear their own costs throughout.
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