Yahoo v. Controller, and Rediff: Business Methods are not patentable.

SPICY IP:

In one of its first major decisions involving patentability of business method patents (available here), the Intellectual Property Appellate Board (IPAB) has ruled (December 8, 2011) that pure business methods are not patentable in India.  This post provides an overview of the decision and its implications for the patent community:  (1) Business methods are not patentable in India; and (2) Any refusal of a patent under section 25(1) of the Act may be appealed to the IPAB as it relates to an order passed under section 15 of the Act, which in effect, may be appealed against under section 117-A of the Act.  Shamnad has discussed the issue of patentability of business methods here, and here.  Warning: Long post follows.    
As a further practice pointer, this case is also important because Yahoo overcame all other objections relating to novelty, and obviousness except the most important one, invention (section 3(k)).  Practitioners may want to cite this case to the Examiners while replying to examiners reports as appropriate. 
Quotable Quote:  Justice Prabha Sridevan and D.P.S. Parmar:  ”…[W]e must place ourselves in 1998, to decide the patentability and what appears so easy and familiar today was new then. Even if we go back in time to 1998 the nature of invention is still a method of doing business. That does not change. There are huge innovations in the computers themselves, but the invention claimed is not for the machine but for the method. From whichever point of time we look at it, it still looks to be a business method.”
Background:  
Overture Services Inc. filed a patent application titled “System and method for influencing a position on a search result listing generated by a computer network search engine”, and the title was later amended