Which of the following principles was emphasized in Novartis AG v. Union of India, commonly known as the Glivec case?

In Novartis AG v. Union of India (2013), the Supreme Court upheld the refusal of a patent for the beta-crystalline form of imatinib mesylate, applying section 3(d) of the Patents Act, 1970, which bars patents for new forms of known substances unless they show enhanced efficacy. The ruling is the leading statement of India’s anti-evergreening principle; territoriality, first sale and dilution were not the issues decided.