The Novartis Precedent and the Ascent of the Therapeutic Efficacy Doctrine The Supreme Court of India's 2013 judgment in Novartis AG v. Union of India & Others  was the tipping point in the history of pharmaceutical patenting and international intellectual property law. One loosely phrased clause in the  Indian Patents Act , Section 3(d), was converted into a powerful doctrine that has, in turn, dictated the intellectual property rights-public health balance ever since. Thro