Satya Infrastructure Ltd. Vs. Satya Infra & Estates Pvt. Ltd

Case Title: Satya Infrastructure Ltd. Vs. Satya Infra & Estates Pvt. Ltd.: Date of Order:7th February, 2013:Case Number:CS(OS) 1213/2011:2013:DHC:653:High Court of Delhi:Hon'ble Mr. Justice Rajiv Sahai Endlaw

Facts:

The plaintiffs, comprising companies under the "Satya Group," claimed long-standing use of the trademark "SATYA" in connection with their real estate and infrastructure businesses since 1986. They alleged that the defendant, Satya Infra & Estates Pvt. Ltd., incorporated in 2009, had adopted the mark "SATYA" in its name with the intent to misappropriate the goodwill and reputation of the plaintiffs and cause confusion among consumers.

The plaintiffs had registered trademarks for "SATYA," "SATYA & Logo," and other variants under the Trade Marks Act, 1999 and had invested substantially in building brand recognition. They filed the suit seeking a permanent injunction, delivery of infringing materials, rendition of accounts, and damages.

Procedural History:

The defendant did not appear despite service of summons.

The court proceeded ex parte against the defendant.

Plaintiffs, through counsel, elected to pursue only the relief of permanent injunction, foregoing damages and other reliefs for expediency.

Issues:

Whether the use of the mark “SATYA” by the defendant in its corporate name constituted infringement of the plaintiffs’ registered trademark and amounted to passing off.

Decision:

The High Court:

Held that the plaintiffs had established long-standing, continuous, and registered use of the "SATYA" mark in relation to real estate and related services.

Found that the defendant's use of "SATYA" in its corporate name was likely to cause confusion and mislead the public into believing an association with the plaintiffs.

Observed that such use amounted to infringement of trademark rights under the Trade Marks Act, 1999.

Granted a permanent injunction restraining the defendant from using the name “Satya Infra & Estates Pvt. Ltd.” or any deceptively similar name or mark.

Provided a three-month period for the defendant to comply before the injunction would take effect.

Directed that a copy of the judgment be served on the Registrar of Companies to initiate rectification of the defendant’s name if necessary.