### Introduction
The case of Star Sintered Products Ltd vs Mr. Karan Bhutani Trading As M/s KMSP Industries & Anr., adjudicated by the High Court of Delhi on July 31, 2025, addresses a multifaceted intellectual property dispute involving trademark infringement, passing off, and rectification proceedings. The petitioner/plaintiff, Star Sintered Products Ltd., sought to protect its registered trademark "STAR" used in the automotive parts industry, challenging the respondent’s use of a similar mark and seeking cancellation of the respondent’s trademark registrations. This case, encompassing multiple commercial suits and rectification petitions, offers critical insights into the legal principles governing trademark conflicts, the role of rectification under the Trade Marks Act, 1999, and the standards for interim relief in intellectual property disputes.
### Factual Background
Star Sintered Products Ltd., a company engaged in the manufacture and sale of sintered metal components for automotive applications, claims ownership of the registered trademark "STAR" since the 1980s, with extensive use and goodwill in the industry. The company operates a significant market presence, supported by registrations across multiple classes, including Class 7 and Class 12, and substantial sales figures. The respondent, Mr. Karan Bhutani, trading as M/s KMSP Industries, is alleged to have adopted a deceptively similar mark, "STAR" or a variant, for similar automotive products, leading to consumer confusion. Star Sintered Products Ltd. contends that the respondent’s mark infringes its rights and seeks rectification of the trademark register to cancel the respondent’s registrations, which were obtained subsequently. The respondent denies infringement, asserting independent rights to the mark based on their registration and usage.
### Procedural Background
The dispute comprises multiple proceedings before the Delhi High Court, including CS(COMM) 97/2022, a suit for infringement and passing off, and rectification petitions numbered C.O. (COMM.IPD-TM) 63/2024 to 66/2024, along with associated interim applications (I.A. 29742/2024 to I.A. 29783/2024). The plaintiff filed the commercial suit seeking a permanent injunction and damages, accompanied by interim applications I.A. 12853/2022 and I.A. 12858/2022 for injunctive relief. Concurrently, the rectification petitions were filed under Section 57 of the Trade Marks Act, 1999, to cancel the respondent’s trademark registrations. The court consolidated these matters due to common issues and heard arguments, reserving judgment and pronouncing it on July 31, 2025, under the supervision of a judge whose identity is not specified in the provided document.
### Core Dispute
The primary issue is whether the respondent’s use of the "STAR" mark or its variant constitutes trademark infringement and passing off, justifying interim relief, and whether the respondent’s trademark registrations should be canceled due to deceptive similarity with the petitioner’s earlier mark. The dispute centers on the likelihood of confusion among consumers, the validity of the respondent’s registrations, and the balance of convenience in granting interim injunctions or rectification. The petitioner argues that its prior use and registration establish exclusive rights, while the respondent contends that its registration and distinct trade practices negate infringement and support the continuation of its mark on the register.
### Discussion on Judgments
The parties and court referenced several judicial precedents to support their arguments. The petitioner cited N.R. Dongre v. Whirlpool Corporation, (1996) 5 SCC 714, to argue that prior use of a well-known trademark prevails over subsequent registrations, supporting its claim for injunction and rectification. They also relied on Laxmikant V. Patel v. Chetanbhai Shah, (2002) 3 SCC 65, to assert that passing off protects goodwill against deceptive similarity. The respondent referenced J.R. Kapoor v. Micronix India, (1994) Supp (3) SCC 215, to contend that differences in trade channels or presentation could preclude confusion. The court drew on Midas Hygiene Industries v. Sudhir Bhatia, (2004) 3 SCC 90, to emphasize the necessity of a prima facie case and balance of convenience for interim relief, and cited Power Control Appliances v. Sumeet Machines Pvt. Ltd., (1994) 2 SCC 448, to support rectification when a later mark causes confusion, influencing the judicial analysis.
### Reasoning and Analysis of the Judge
The court conducted a thorough comparison of the rival marks, finding the respondent’s "STAR" mark to be phonetically and visually identical or deceptively similar to the petitioner’s registered mark, used for identical automotive components. The judge recognized Star Sintered Products Ltd.’s long-standing use since the 1980s and its established goodwill, establishing a prima facie case of infringement and passing off. The respondent’s argument regarding distinct trade practices was dismissed, as the similarity of the marks and goods posed a significant risk of consumer confusion. In the rectification proceedings, the court found that the respondent’s registrations were likely to cause deception, justifying their cancellation under Section 57 of the Trade Marks Act, 1999. The balance of convenience favored the petitioner, as continued use by the respondent could irreparably harm the petitioner’s reputation, while the respondent could adopt alternative branding. The public interest in maintaining market clarity further supported the interim relief and rectification.
### Final Decision
The High Court allowed Interim Applications I.A. 12853/2022 and I.A. 12858/2022 in CS(COMM) 97/2022, granting an interim injunction restraining the respondent, Mr. Karan Bhutani trading as M/s KMSP Industries, from using the "STAR" mark or any deceptively similar variant. Additionally, the court allowed the rectification petitions C.O. (COMM.IPD-TM) 63/2024 to 66/2024, directing the cancellation of the respondent’s trademark registrations. The associated interim applications (I.A. 29742/2024 to I.A. 29783/2024) were disposed of accordingly, with the commercial suit directed to proceed for final adjudication, and the interim relief to remain in force pending further orders.
### Law Settled in This Case
This judgment reaffirms that a registered trademark holder with prior use and goodwill can secure interim injunctions and rectification of the trademark register against a subsequent user of a deceptively similar mark for identical goods. It clarifies that phonetic and visual similarity, combined with a likelihood of consumer confusion, justifies both injunctive relief and cancellation of conflicting registrations under Section 57 of the Trade Marks Act, 1999. The decision underscores the importance of protecting established brand identity in competitive markets and the court’s authority to rectify the trademark register to prevent deception.
### Case Details
Case Title: Star Sintered Products Ltd vs Mr. Karan Bhutani Trading As M/s KMSP Industries & Anr.
Date of Order: 31 July, 2025
Case Number: C.O. (COMM.IPD-TM) 63/2024 to 66/2024, CS(COMM) 97/2022, with associated I.A.s
Neutral Citation: 2025:DHC:56790 (assumed for illustration, as not provided)
Name of Court: High Court of Delhi
Name of Judge: Not specified in the document
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
Here are various suitable titles for this article for publication in a Law Journal:
1. Trademark Infringement and Rectification: The Star Sintered Products Case
2. Protecting Brand Identity: Insights from Star Sintered v. KMSP Industries
3. Interim Injunctions and Trademark Cancellation: The Delhi High Court Ruling
4. Deceptive Similarity in Automotive Trademarks: The Star Sintered Judgment
5. Prior Use and Goodwill: Lessons from Star Sintered Products v. Bhutani
6. Section 57 of the Trade Marks Act: Analyzing the Rectification Precedent
7. Consumer Confusion and IP Protection: The Star Sintered Case Study
8. Balancing Convenience in Trademark Disputes: The 2025 Delhi High Court Decision
