Case Title: Rainbow Children’s Medicare Limited Vs Rainbow Healthcare Court: High Court of Karnataka, Bengaluru Date of Order: 23rd April 2025 Case No.: COMAP No. 286 of 2024 & COMAP No. 287 of 2024 Hon’ble Mr. Justice V. Kameswar Rao & Hon’ble Mr. Justice T. M. Nadaf
Facts:
Rainbow Children’s Medicare Limited, based in Hyderabad, has been operating under the “Rainbow” brand since 1998. It has established its presence across multiple cities, including Bengaluru. Rainbow Healthcare, operating in Bengaluru since 2013, also uses the name “Rainbow Healthcare Hospital,” creating a dispute over the use of the “Rainbow” mark. The plaintiff claims prior adoption and use of the trademark in relation to healthcare services, asserting their rights over the mark.
Procedural History:
The Court initially passed interim orders granting injunctions in favor of Rainbow Healthcare, which the plaintiff challenged through appeals filed under the Commercial Courts Act. The Trial Court (Addl. City Civil and Sessions Judge, Bengaluru) had vacated interim injunctions earlier issued in April 2023, dismissing the interlocutory applications (IAs). The appeals seek to set aside these dismissals and restore the earlier interim relief.
Issues:
Whether the trial court was justified in vacating the interim injunctions despite finding that Rainbow Healthcare had established a prima facie case?Whether the interim orders granted by the trial court cause irreparable harm to Rainbow Children’s Medicare Limited?Whether the court should prioritize public interest and the balance of convenience in granting interim relief in cases involving trademarks and business names.
Decision:
The High Court observed that courts should not grant interim orders solely based on a prima facie case without considering the balance of convenience, public interest, and potential prejudice. The Court found that the Trial Court failed to appropriately consider these factors and had wrongly vacated the interim orders. Consequently, it allowed the appeals, setting aside the orders passed by the Trial Court, thereby reinstating the interim relief to protect Rainbow Children’s Medicare Limited’s rights.
