SML Limited, a manufacturer of agrochemical and fertiliser products, sued Mohan & Company and Dharmaj Crop Guard Limited before the Himachal Pradesh High Court, alleging that the defendants were selling a product that infringed the patent behind SML's own ZeekaSulf brand. The suit, registered as Commercial Suit No. 7 of 2023, sought a permanent injunction and damages. Alongside it, SML filed an application for interim relief, OMP(I) No. 324 of 2023, asking the court to restrain Mohan & Company and Dharmaj Crop Guard from manufacturing, selling or offering the allegedly infringing product until the suit was finally decided.
To get an interim injunction at that stage, SML had to show more than a patent on its books and a rival product in the market. It had to make out, at least prima facie, that the Himachal Pradesh High Court had the territorial jurisdiction to hear the dispute in the first place, since neither defendant was shown to be based in the state. SML's case rested on an alleged sale of the infringing product by a retailer within Himachal Pradesh, which it treated as sufficient to anchor the suit there and to justify an injunction pending trial. That single transaction became the fulcrum on which the entire application turned.
The court was not satisfied. In an order dated 15 October 2026, it held that the material SML had placed on record did not prima facie establish territorial jurisdiction in Himachal Pradesh. It went further and found a gap at the heart of SML's own evidence: there was no sufficient proof that Dharmaj Crop Guard or Mohan & Company had actually supplied the product in question to the retailer SML relied on to found jurisdiction. Without that link, SML could not show either that the court had the power to hear the case at an interim stage, or that the defendants were making the kind of sales within the state that would justify restraining them before trial. The interim injunction application was dismissed on both grounds.
Dismissal of the interim application is not the end of the road for SML, and the order does not touch the question of infringement itself. Commercial Suit No. 7 of 2023 remains pending, and SML can still press its claim that the ZeekaSulf patent is being infringed, provided it can establish jurisdiction and make its case at trial on fuller evidence than it offered at the interim stage. What the order does, for now, is remove any restraint on Mohan & Company and Dharmaj Crop Guard selling the product in question while that suit runs its course, which for a seasonal agrochemical product sold ahead of a specific sowing cycle can matter a great deal commercially to both sides of the dispute.
Patent holders litigating against distributors spread across several states often pick their forum by pointing to a single sale traced to that state, sometimes arranged through an investigator rather than found in the ordinary course of trade. Courts hearing patent suits have grown increasingly reluctant to treat that kind of isolated purchase as enough to found jurisdiction or to justify an injunction, insisting instead on evidence of commercial-scale dealing within the state concerned. The Himachal Pradesh High Court's order fits that pattern: one alleged sale to one retailer, without more, did not persuade the court that it had either the jurisdiction or the evidentiary basis to restrain the defendants before trial.
Dharmaj Crop Guard, a listed company, reported the order to the stock exchanges as a material development in pending litigation, confirming that SML's application for interim injunction stood dismissed and that the main suit continues. For SML, the setback is confined to the interim stage and the question of infringement remains open. For Dharmaj Crop Guard and Mohan & Company, it means they can keep selling the product in question while the underlying patent dispute is argued out on its merits, with the jurisdiction question likely to resurface once the suit itself is taken up.