What happens if we miss the Form 27 deadline, or get it wrong?

Rule 131(2) allows an extension of up to three months on a request in Form 4 with fees. Beyond that, a request under Rule 138 may be available for a further period of up to six months, again on payment.

On consequences, the position changed on 1 August 2024, when the intellectual property provisions of the Jan Vishwas (Amendment of Provisions) Act, 2023 came into force:

• Failure to furnish information under Section 122(1) now attracts a penalty of up to INR 1,00,000, with a further penalty of INR 1,000 for each day the failure continues. The earlier fine of up to INR 10,00,000 no longer applies.

• Furnishing false information under Section 122(2) has been decriminalised. Imprisonment has been removed and replaced by a penalty of 0.5% of total sales, turnover or gross receipts as computed in the audited accounts, or INR 5 crore, whichever is lower. For a company of any size, this is a far heavier exposure than the penalty for simply not filing — accuracy matters more than punctuality.

These penalties are now determined administratively rather than through the criminal courts. The Patents (Amendment) Rules, 2025, notified on 25 November 2025, inserted a new chapter governing adjudication of penalties and appeals: complaints are filed electronically before an adjudicating officer in Form 32, with appeals to the appellate authority in Form 33.