Castrol Limited Vs Sanjay Sonavane

Factual and procedural background

Castrol Limited, a well-known manufacturer of engine oils and lubricants, filed two separate commercial suits in the Delhi High Court against Sanjay Sonavane and others. In the first suit Castrol sought a declaration that its 3X trademark did not infringe Sonavane’s 3P mark and an injunction to stop him from issuing groundless threats of legal action. This suit arose after a police raid on one of Castrol’s authorised distributors triggered by a complaint and FIR filed by Sonavane. In the second suit Castrol sued Sonavane along with several newspapers, a YouTube channel and other media outlets for publishing allegedly disparaging articles and videos about the raid which tarnished Castrol’s reputation. The single judge dismissed the second suit holding it was barred under Order II Rule 2 of the Code of Civil Procedure because both suits arose from the same set of facts and Castrol should have claimed all reliefs in the first suit. Aggrieved by this order Castrol filed the present appeal before the division bench.

Dispute in question

The central dispute was whether the second suit filed by Castrol was barred by Order II Rule 2 CPC on the ground that it arose from the same cause of action as the first suit and that Castrol had omitted to claim the reliefs of disparagement and media takedown in the earlier proceeding.

Reasoning and decision of court

The division bench examined both plaints in detail and the timeline of events. The court found that while the initial police raid and Sonavane’s complaint formed the background, the second suit was based on distinct subsequent events including specific media publications and WhatsApp messages circulated after the first suit had already been filed. The bench reviewed several Supreme Court judgments on Order II Rule 2 CPC and held that the causes of action in the two suits were not identical and the reliefs claimed in the second suit could not have been sought in the first suit at the time it was instituted. The court accordingly allowed Castrol’s appeal set aside the single judge’s order dismissing the second suit and directed that the second suit be restored and proceed in accordance with law.

Legal point settled in this case

A second suit is not barred by Order II Rule 2 CPC merely because it relates to events connected with the first suit if the causes of action are distinct or the facts and reliefs in the later suit arose or came to the plaintiff’s knowledge only after the first suit was filed.

Castrol Limited Vs Sanjay Sonavane:20.04.2026:RFA(OS)(COMM) 38/2025:2026:DHC:3210-DB: High Court of Delhi, Hon’ble Mr. Justice C. Hari Shankar and Hon’ble Mr. Justice Om Prakash Shukla.

Disclaimer: Donot treat this as substitute for legal advise as it may contain subjective errors.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

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