Brief Introductory Head Note Summary of Case
This case was heard in the High Court of Delhi and concerns a legal dispute between The Coca-Cola Company, its authorized bottler, and M/s Raj Trade Links regarding the handling and production of documents in a trademark and commercial litigation context. The matter especially involved an application by the defendant for the belated filing of Income Tax Returns and other documents claimed to be necessary for their defense. The core issue was whether, under the Commercial Courts Act regime, a litigant can file documents long after the closure of the plaintiff’s evidence, and whether grounds such as the pandemic legitimately justified such delay. The Court ultimately refused the application, emphasizing the importance of timely procedural compliance to uphold speedy commercial litigation.
Factual Background
The Coca-Cola Company, as Plaintiff No. 1, operates in the business of manufacturing and selling beverage concentrates and related products, while Plaintiff No. 2 is its authorized Indian bottler. Together, they distribute beverages in specified containers, which are to be recycled and returned for refilling. Defendant No. 2, operating as a sole proprietorship under the name Raj Trade Links, collected empty bottles from the market. The plaintiffs alleged the defendant hoarded large stocks of Coca-Cola bottles, creating a market shortage and possibly aiding the supply of used bottles for refilling with spurious beverages. This prompted the plaintiffs to file a lawsuit seeking an injunction, damages, and delivery-up for trademark infringement and unfair competition. During litigation, the defendant sought to file additional evidence, specifically their Income Tax Returns for 2007-08 to 2011-12, which they argued were necessary to prove alleged damages and claims in their counterclaim.
Procedural Detail
The suit was initially instituted in 2007, and in 2018 it was converted into a commercial suit. Defendant No. 2’s written statement was taken on record in September 2007, and the litigation involved multiple directions regarding filing of evidence by both sides, with several delays and adjournments mainly on the part of the defendants. Plaintiffs closed their evidence in March 2018 after several years of proceedings. Defendant No. 2 was repeatedly granted opportunities but further delayed, finally seeking to submit the disputed additional documents as late as May 2024. Plaintiffs objected to the application, arguing that under the amended Commercial Courts Act and Civil Procedure Code, such belated filings should not be allowed except for substantial and justified reasons, especially considering the impact on expeditious justice.
Core Dispute
The primary issue was whether Defendant No. 2 should be permitted to file "additional documents" (specifically income tax records from 2007-2012) at a very late stage in the proceedings, when the evidence of the plaintiffs had already closed years prior. The defendant attributed their delay to difficulties caused by the pandemic, among other reasons. Plaintiffs countered that allowing the documents would unfairly prejudice their case, introduce new facts not previously pleaded, and was not adequately justified under the rules designed for expeditious disposal of commercial disputes.
Detailed Reasoning and Discussion by Court
The Court analyzed various provisions under the Code of Civil Procedure as amended by the Commercial Courts Act, highlighting the need for all parties to disclose documents in their possession at the time of filing their pleadings unless there is good cause for later submission. The Court discussed the legal framework governing document production, including Orders XI, VIII, and XVIII of the CPC and corresponding sections of the Commercial Courts Act, all of which underline the principles of fairness and early disclosure.
Citing several precedents (such as Scindia Potteries Services P. Ltd. v. J.K. Jain, 2012 SCC OnLine Del 5296; Societe DES Produits Nestle S.A. v. Essar Industries, 2016 SCC OnLine Del 4279; and Ramanand v. Delhi Development Authority, 2016 SCC OnLine Del 4925), the judgment reasoned that litigants—especially commercial entities—are expected to act diligently. The Court found that ample opportunities were given to Defendant No. 2, who nonetheless did not disclose the necessary documents until many years later, well after the closure of the plaintiffs’ evidence.
The Court also analyzed the explanation regarding the pandemic and held that since the documents in question pre-dated the pandemic, the justification offered by Defendant No. 2 did not hold. Allowing such a filing would defeat the objective of the Commercial Courts Act, which is aimed at preventing delay and expediting commercial litigation. The legal discussion referenced law, procedure, specific case law, and the objects and reasons of the statute itself.
Decision
The Court decided that no valid reason existed for permitting such belated filing of documents. The defendant failed to show reasonable cause or diligence. Allowing the request would compromise the orderly conduct of proceedings under the Commercial Courts Act and prejudice the plaintiffs, who had already closed their evidence. Thus, the Court dismissed Defendant No. 2’s application for taking the additional documents on record. A consequential application for summoning witnesses to prove those additional documents was also dismissed as infructuous.
Concluding Note
This case underscores the judiciary’s approach towards strict procedural compliance in commercial disputes and highlights that delay, especially in document production, will not be condoned unless exceptional and well-justified reasons exist. The judgment reaffirms the commitment of commercial courts to expedite proceedings and discourages casual or negligent conduct on the part of parties involved.
Case Title: The Coca-Cola Company & Anr. v. M/s Raj Trade Links & Anr.
Order Date: November 24, 2025
Case Number: CS(COMM) 439/2018, CC 970/2007
Neutral Citation: 2025:DHC:5694
Court: High Court of Delhi
Hon'ble Judge: Justice Tejas Karia
Disclaimer: The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
Suggestions for Suitable Titles:
Timeliness and Diligence in Commercial Litigation: Lessons from The Coca-Cola Company vs. Raj Trade Links
The Imperative of Procedural Rigor in Trademark Disputes under the Commercial Courts Act
Document Production and Delay: Judicial Trends in Indian Commercial Law
Ensuring Swift Justice in Commercial Suits: An Analytical Perspective
The Balance between Procedural Fairness and Expedition: Recent Directions from the Delhi High Court
Delhi High Court Bars Late Document Filing in Decade-Old Coca-Cola Bottle Hoarding Case
New Delhi, November 24, 2025: The High Court of Delhi, in The Coca-Cola Company & Anr. Vs. M/s Raj Trade Links & Anr. (CS(COMM) 439/2018, CC 970/2007), presided by Hon'ble Mr. Justice Tejas Karia, rejected Defendant No. 2's bid to file Income Tax Returns (2007-2012) as additional evidence in this trademark infringement suit.
Plaintiffs accused the defendants of hoarding empty Coca-Cola bottles, causing shortages and risking spurious refills, after the suit originated in 2007 and became commercial in 2018. Defendant No. 2 claimed pandemic delays prevented earlier access via their chartered accountant to support counterclaim damages.
Applying CPC Order XI Rule 10 as amended by the Commercial Courts Act, Justice Karia highlighted the defendant's chronic delays, multiple unutilized opportunities post-plaintiffs' 2018 evidence closure, and weak justifications predating COVID. Citing Scindia Potteries (2012 SCC OnLine Del 5296) and Nestle v. Essar (2016 SCC OnLine Del 4279), the court prioritized expeditious trials, dismissing the application and a linked witness summons plea. Evidence recording set for January 12, 2026.
Disclaimer:This is for general information only and should not be construed as legal advice as it may contain human errors in perception and presentation: Advocate Ajay Amitabh Suman, IP Adjutor (Patent & Trademark Attorney), High Court of Delhi
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