Case Title: Lifestyle Equities C.V. & Another Vs. Amazon Technologies Inc.
Order Date: 7th October 2025
Case Number: Civil Appeal No. 19767 of 2025
Neutral Citation: 2025 INSC 1190
Name of Court: Supreme Court of India
Hon’ble Judges: J.B. Pardiwala J. and K.V. Viswanathan J.
The case before the Supreme Court arose out of a trademark infringement suit filed by Lifestyle Equities C.V. and its subsidiaries against Amazon Technologies Inc. and others. Lifestyle Equities claimed proprietary rights over the well-known trademark "Beverly Hills Polo Club" (BHPC), used extensively in garments, footwear, and lifestyle products. The plaintiffs alleged that Amazon Technologies and related parties had unlawfully used and sold goods bearing a deceptively similar mark, resulting in infringement, dilution of goodwill, and unfair competition. Lifestyle sought permanent injunctions, damages, and rendition of accounts from the defendants.
The suit was initially filed in the Delhi High Court and proceeded ex parte against Amazon Technologies after it failed to file a written statement despite summons. The High Court granted an interim injunction restraining the defendants from using the infringing logo and later decreed permanent injunctions along with damages amounting to Rs. 336 crores (approximately USD 38.78 million) and costs of over Rs. 3 crores. The damages awarded were based on computations submitted by Lifestyle during trial, which substantially enhanced the principal claim from an initial amount of Rs. 2 crores in the plaint to Rs. 336 crores in written submissions, without formal amendment or notice to defendants.
Amazon Technologies challenged the decree in appeal before the Division Bench of the Delhi High Court, contending various procedural and substantive irregularities including defective service of summons, lack of proper pleadings supporting massive damages awarded, and absence of evidence linking Amazon Technologies to infringement. The Division Bench accepted the appeal and granted stay of the judgment and decree without requiring Amazon to deposit the decretal amount pending appeal. The Division Bench noted serious infirmities in the proceedings before the Single Judge, including failure to serve summons properly, improper ex parte proceedings, and lack of pleading on Amazon's involvement specifically in infringing activities. The Division Bench also observed that the damages claim was grossly inflated without amendment of pleadings or notice to Amazon. Consequently, the stay was granted as an exceptional case involving egregious procedural lapses and patent illegalities in the original suit proceedings.
Lifestyle Equities filed a Special Leave Petition in the Supreme Court seeking to set aside the stay and enforcement of the decree. The Supreme Court thoroughly examined the contested issues, analysing the legal provisions under Order XLI Rules 5, 13, 53 of the Civil Procedure Code (CPC) governing stay of execution of money decrees pending appeal. The Court emphasized that while the general rule requires deposit or security to stay execution, the appellate court has a discretionary power to grant unconditional stay in exceptional cases involving egregious perversion or patent illegality in the judgment. The Apex Court also carefully reviewed precedents on service of summons, holding that summons must be properly served for jurisdiction and valid ex parte proceedings, citing the strict principles of natural justice. It was found that summons were never properly served on Amazon Technologies, rendering its ex parte treatment legally flawed.
The Court rejected Lifestyle’s contention that the exorbitant damages awarded could be sustained without formal pleading and notice, ruling that exact claims for damages must be pleaded and cannot be substantially enhanced post-trial without amendment. The Supreme Court observed that the original decree suffered from procedural infirmities and unreasonable enhancement of damages without due process. The Court recognized that the Division Bench had followed proper legal exercises to grant an unconditional stay to prevent grave miscarriage of justice.
In conclusion, the Supreme Court confirmed the Division Bench’s order granting unconditional stay of execution of the money decree against Amazon Technologies. The Court held that an appellate court may grant unconditional stay of execution in exceptional cases where the decree is egregiously perverse, riddled with patent illegality, or the suit procedure is fundamentally flawed. The judgment clarified the balance between securing decree-holder rights and safeguarding due process for judgment debtors, underscoring that stays are not automatic but must be granted based on sufficient cause and discretion.
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Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
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