It is well known that the Buddhist theory of momentariness is refuted in the Nyayasutra 3.2.10-17. However, only a few studies have so far been made on early Naiyayika' refutations of this theory. In the present paper I have examined how Vatsyayana criticizes the proof of momentariness, which Rospatt  has pointed out is similar to that dealt with in the Mahayanasutralamkara and which he calls ‘the deduction of momentariness from change’.
Although Vatsyayana makes no mention of the proof, he obviously argues against it. For he discusses the following universal concomitance (niyama): All the objects that have a continuous process of growth and decay [no sooner arise than they pass], just like the body (sarvasu vyaktisu upacayapacayaprabandhah sariravad).
Vatsyayana refutes this universal concomitance by pointing out that the concomitance is not observed in a crystal.
The important point to note is that Naiyayikas from Uddyotakara on deal mainly with the proof of momentariness from spontaneous destruction (vinasitvanumana), which is also argued in the Mahayanasutralamkara.