Brief Introductory Head Note Summary of Case
This case involves a dispute over copyright protection for artistic labels used in the edible oil business. Rajani Products, a partnership firm, filed a petition in the Delhi High Court to cancel a copyright registration held by Madhukar Varandani, who runs Naturalindia Oils and Proteins. The main issue was whether Varandani's label, which included a Swastik device, copied Rajani Products' earlier labels too closely, making it unoriginal and unworthy of copyright protection. The court examined if the challenged label was a substantial imitation of the original works, leading to its removal from the copyright register. This decision highlights how courts protect original creative works in business branding while preventing unfair copying that could harm established reputations.
Factual Background
Rajani Products is a partnership firm that makes and sells edible oils and similar products. They claim to have started using the Swastik mark, including labels like "Swastik No. 1" and a Swastik logo, back in 1975 through their earlier owners. The word "Swastik" is a key part of their branding. They have registered several trademarks for these, such as one for "Swastik No. 1" under application number 411334 for mustard and til oil, valid until 2034, and another under 1055218 for various edible oils, valid until 2031. Two more applications are pending. Rajani Products also holds copyright registrations for their artistic labels: one is A-45417/1984 for a Swastik label, and another is A-46097/1984 for a similar Swastik label. These copyrights protect the unique designs they created for their products.
On the other side, Madhukar Varandani runs a business called Naturalindia Oils and Proteins, which also deals in edible oils. He started using labels like "Shubharambh" with a Swastik device and "Niwai" with a Swastik device for his products. Rajani Products did not mind the words "Shubharambh" or "Niwai" but objected strongly to the use of the Swastik device, saying it looked too much like theirs. Varandani got a copyright registration in 2019 for his artistic work titled "NIOP Niwai in English and Hindi with Device of Swastik," numbered A-128046/2019. In this design, the Swastik device is a central feature.
Rajani Products learned about this copyright when Varandani mentioned it in a defense document during a separate lawsuit. Before that, Rajani Products had already sued Varandani in a lower court for using those labels, and on February 19, 2021, the District Judge in South Saket Court, New Delhi, granted a temporary order stopping Varandani from using the "Shubharambh" and "Niwai" labels with the Swastik device. Feeling harmed by the copyright registration, Rajani Products asked the high court to cancel it, arguing it was not original and copied their designs.
Procedural Detail
The case started when Rajani Products filed a petition under Section 50 of the Copyright Act, 1957, in the Delhi High Court, numbered C.O.(COMM.IPD-CR) 16/2024. This section allows someone affected by a wrong copyright entry to ask for its removal. The court issued a notice on August 30, 2024, which Varandani's lawyer accepted, and gave him four weeks to reply. On December 13, 2024, the court noted no reply was filed and gave another six weeks. Then, on April 29, 2025, the court gave a final chance of four weeks to file a reply, but with a condition to pay 10,000 rupees as costs, and asked both sides to submit short written summaries. Despite this, Varandani did not file a reply, so on September 8, 2025, the court closed his chance to respond. The government's lawyer for the copyright office opposed canceling the registration but did not provide detailed arguments. The case was heard without Varandani's full defense, and the judgment was delivered on November 24, 2025.
Core Dispute
The main question was whether Varandani's copyrighted label was original enough to stay on the copyright register or if it was too similar to Rajani Products' earlier labels, making it a copy that should be removed. Rajani Products argued they were the first to use the Swastik design in edible oil labels since 1975, and Varandani's version imitated it closely, including the shape, placement, and colors. They said this copying harmed their business reputation. Varandani did not defend himself properly since he missed filing a reply, but the copyright office opposed the cancellation. The court had to decide if Rajani Products was truly affected and if the challenged label met the legal test for originality under copyright law.
Detailed Reasoning and Discussion by Court Including on Judgement with Complete Citation Referred and Discussed for Reasoning
The court began by noting that since Varandani did not file a reply despite many chances, the facts presented by Rajani Products stood unchallenged. Under Section 50 of the Copyright Act, 1957, the court explained that this provision allows the removal of a copyright entry if it was wrongly made or harms someone. It can be requested by any "person aggrieved," meaning someone directly affected by the registration. The court found Rajani Products qualified as aggrieved because they own registered copyrights for similar Swastik labels, and both parties sell the same type of products like edible oils. Allowing Varandani's registration to stay could weaken Rajani Products' brand and goodwill, as customers might confuse the products.
To decide if the label should be removed, the court discussed what makes an artistic work original under copyright law. It stressed that copyright protects only original creations, not copies. The court referred to a previous case to explain how to compare labels: Marico Ltd. v. Jagit Kaur, 2018 SCC OnLine Del 8488. In that case, the Delhi High Court said that when checking if one label copies another, you look at the overall look and main features, not tiny details side by side. You consider things like color schemes, object arrangements, and if the copy could fool an average person. The court quoted a part from that judgment where it compared two coconut oil labels. One had a similar color scheme, coconut tree, and broken coconuts, leading the court to call it a "colorful imitation or substantive reproduction." The Marico case also borrowed from an older Supreme Court decision: Parle Products (P) Ltd. v. J.P. & Co., Mysore, (1972) 1 SCC 618. There, the Supreme Court said you judge similarity by broad features that might mislead a normal buyer, not by nitpicking differences. For example, in Parle, two biscuit wrappers had similar sizes, colors, a girl with raised arm, animals, and a farm background, so one was seen as deceptively similar. The court explained that even if not identical, if the overall effect confuses people, it's a problem. It emphasized that ordinary buyers aren't detectives like Sherlock Holmes; they can easily mix up similar designs seen days apart.
Applying this to the current case, the court compared the designs visually. Rajani Products' labels from 1984 showed a Swastik symbol in a circle with specific colors and placement. Varandani's 2019 label had a very similar Swastik device, also in a circle, with matching background colors. The court said the Swastik was the key part in both, and the similarities in color and layout made Varandani's a "substantial imitation or reproduction." Since it copied essential elements without originality, it didn't deserve copyright protection. The court concluded that keeping such a non-original work on the register was wrong under the Copyright Act, 1957.
Decision
The court allowed the petition and ordered the cancellation of Varandani's copyright registration A-128046/2019. It directed the copyright office to remove it from the register and update their website within four weeks. The petition and any related application were closed.
Concluding Note
This case shows the importance of originality in copyright for business labels. It reminds companies to create unique designs rather than borrow from others, as courts will step in to protect earlier creators and prevent confusion in the market. By canceling the registration, the court upheld fair competition in the edible oil industry, ensuring that goodwill built over years isn't unfairly diluted.
Case Title: Rajani Products Vs Madhukar Varandani, Proprietor of Naturalindia Oils and Proteins & Anr. Order Date: November 24, 2025 Case Number: C.O.(COMM.IPD-CR) 16/2024 Neutral Citation: 2025:DHC:10368 Name of Court: High Court of Delhi at New Delhi Name of Hon'ble Judge: Hon'ble Mr. 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
Suggested Titles for This Legal Analytical Article
- Protecting Originality in Branding: Analyzing the Delhi High Court's Decision in Rajani Products v. Madhukar Varandani on Copyright Rectification
- Swastik Symbol Dispute: A Deep Dive into Copyright Cancellation for Imitative Artistic Works in Edible Oil Labels
- Judicial Safeguards Against Copycat Labels: Lessons from the 2025 Delhi High Court Ruling on Section 50 of the Copyright Act
- Originality Threshold in Artistic Works: Unpacking the Reasoning in Rajani Products' Successful Petition Against Infringing Copyright
- Balancing Trademark and Copyright in Business: An Examination of Substantial Similarity in the Varandani Label Cancellation Case
In a significant ruling on intellectual property rights, the High Court of Delhi at New Delhi, through Hon'ble Mr. Justice Tejas Karia, delivered judgment on November 24, 2025, in the case titled Rajani Products vs Madhukar Varandani, Proprietor of M/s Naturalindia Oils and Proteins & Anr., bearing case number C.O.(COMM.IPD-CR) 16/2024. The court ordered the cancellation of a copyright registration for an artistic label featuring the Swastik device, deeming it a substantial imitation lacking originality.
The dispute centered on Rajani Products, a firm in the edible oil business, challenging the 2019 copyright registration (No. A-128046/2019) held by Madhukar Varandani for his "NIOP Niwai" label with a Swastik symbol. Rajani Products claimed prior use of similar Swastik-based labels since 1975, backed by their own 1984 copyright registrations and trademarks. The court noted that Varandani failed to file a reply despite multiple opportunities, leaving the petitioner's claims unchallenged. Applying Section 50 of the Copyright Act, 1957, which allows rectification of erroneous entries, the judge ruled that Rajani Products was an aggrieved party due to potential dilution of their goodwill in the same market.
Justice Karia compared the labels, highlighting similarities in the Swastik device, color schemes, and placement, and cited precedents like Marico Ltd. v. Jagit Kaur (2018 SCC OnLine Del 8488) and Parle Products (P) Ltd. v. J.P. & Co., Mysore ((1972) 1 SCC 618) to emphasize that broad features must be examined for deceptive similarity, not minute differences. Finding the impugned work unoriginal, the court expunged it from the Copyright Register and directed the Controller General of Patents, Designs and Trade Marks to update records accordingly.
This decision underscores the judiciary's role in protecting original artistic works in branding, particularly in competitive sectors like edible oils, where visual imitation can mislead consumers.
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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In a significant ruling on intellectual property rights, the High Court of Delhi at New Delhi, through Hon'ble Mr. Justice Tejas Karia, delivered judgment on November 24, 2025, in the case titled Rajani Products vs Madhukar Varandani, Proprietor of M/s Naturalindia Oils and Proteins & Anr., bearing case number C.O.(COMM.IPD-CR) 16/2024. The court ordered the cancellation of a copyright registration for an artistic label featuring the Swastik device, deeming it a substantial imitation lacking originality.
The dispute centered on Rajani Products, a firm in the edible oil business, challenging the 2019 copyright registration (No. A-128046/2019) held by Madhukar Varandani for his "NIOP Niwai" label with a Swastik symbol. Rajani Products claimed prior use of similar Swastik-based labels since 1975, backed by their own 1984 copyright registrations and trademarks. The court noted that Varandani failed to file a reply despite multiple opportunities, leaving the petitioner's claims unchallenged. Applying Section 50 of the Copyright Act, 1957, which allows rectification of erroneous entries, the judge ruled that Rajani Products was an aggrieved party due to potential dilution of their goodwill in the same market.
Justice Karia compared the labels, highlighting similarities in the Swastik device, color schemes, and placement, and cited precedents like Marico Ltd. v. Jagit Kaur (2018 SCC OnLine Del 8488) and Parle Products (P) Ltd. v. J.P. & Co., Mysore ((1972) 1 SCC 618) to emphasize that broad features must be examined for deceptive similarity, not minute differences. Finding the impugned work unoriginal, the court expunged it from the Copyright Register and directed the Controller General of Patents, Designs and Trade Marks to update records accordingly.
This decision underscores the judiciary's role in protecting original artistic works in branding, particularly in competitive sectors like edible oils, where visual imitation can mislead consumers.
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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