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John Richard Brady v Chemical Process Equipments

John Richard Brady v Chemical Process Equipments (Delhi High Court, 1987): an early Indian recognition of breach-of-confidence protection for trade secrets absent any dedicated statute.

Reviewed by Ravi SisodiaLast reviewed 29 August 2026Case citatorCurrent source control

Finin2min Summary — in 2 Minutes

John Richard Brady v Chemical Process Equipments (Delhi High Court, 1987): an early Indian recognition of breach-of-confidence protection for trade secrets absent any dedicated statute.

Official source and legal ownership

Legal ownerSupreme Court / High Courts / Controller
Source statusOfficially sourced
Review date2026-08-29
Primary sourceJohn Richard Brady v Chemical Process Equipments

Facts and background

Brady shared confidential technical drawings and know-how with the defendant in connection with a proposed business collaboration; the collaboration did not proceed, but the defendant allegedly used the confidential information to manufacture similar equipment independently.

The issue

Whether Indian law protects confidential technical information and trade secrets shared in a business relationship, given that India (unlike some jurisdictions) has no dedicated trade secrets statute.

Holding and ratio

The Delhi High Court granted relief based on the equitable doctrine of breach of confidence, holding that information shared in confidence for a limited purpose cannot be used or disclosed for another purpose without the discloser's consent, applying general equitable principles rather than any specific trade-secrets statute.

Why this case matters

This remains a foundational Indian case for trade secret protection through the breach-of-confidence doctrine, illustrating how Indian courts have filled the gap left by the absence of dedicated trade secrets legislation using established equitable principles.