Case Title: Steelcase Inc. Vs. Mr. K.J. Bhuta and Others Date of Order: May 28, 2025 Case Number: CS(COMM) 1180/2018 Neutral Citation: 2025:DHC:4521 Court: High Court of Delhi Judge: Hon’ble Mr. Justice Saurabh Banerjee
Facts:
Steelcase Inc. filed a suit for infringement of its registered trademark "STEELCASE" against Mr. K.J. Bhuta, who operates as "M/s. Steel Case India Private Limited." The defendant claimed prior use of the trade name since 1981 and contested the plaintiff’s rights based on abandoned applications and the descriptive nature of the mark.
Decision:
The Court dismissed the defendant's application under Section 124(1)(b)(ii) of the Trade Marks Act to specify that the trademark "STEELCASE" was invalid or descriptive. It found that the defendant failed to demonstrate a prima facie case of invalidity or that the plaintiff's mark was merely descriptive. The Court clarified that the trademark was distinctive due to continuous use by the plaintiff and that mere prior use by defendant did not establish prior rights sufficient to oppose the registration.
Law Settled:
- The Court clarified the scope of Section 124(1)(b)(ii) of the Trade Marks Act regarding prima facie tenability of invalidity claims.
- Registration and ongoing use of a mark over time can establish distinctiveness.
- Abandoned applications or prior use alone do not necessarily invalidate a trademark absent proof of descriptiveness or prior rights.
