IP.ADJUTOR

Tuesday, February 17, 2026

Pawan Kumar Goel Vs. Dr. Dhan Singh

Introduction

In patent infringement litigation, a plaintiff who initiates a suit alleging unauthorized use of a patented process often faces the challenge of proving infringement based on the defendant's actual manufacturing methods. When new evidence emerges during proceedings that undermines the foundational claim of infringement, the plaintiff may seek to withdraw the suit. However, Indian courts scrutinize such requests carefully, particularly when the plaintiff attempts to withdraw conditionally to preserve the right to file a fresh suit later on the same grounds. The Delhi High Court's decision in this case illustrates the strict application of withdrawal provisions under the Code of Civil Procedure, emphasizing that a plaintiff cannot use withdrawal as a tool to revive a meritless claim or hedge against future contingencies while avoiding consequences for pursuing weak or baseless litigation.

Factual Background

The plaintiff, Pawan Kumar Goel, owns Indian Patent No. 369150, which covers a novel process for extracting Alpha Yohimbine (also known as Rauwolscine) with purity greater than 90% from Rauwolfia canescens/tetraphylla. He filed the suit claiming that the defendants, Dr. Dhan Singh and another, were infringing this patent by using the same or similar process involving Rauwolfia canescens/tetraphylla to produce the compound commercially. The plaintiff sought a permanent injunction, delivery up of infringing stocks, accounts of profits, damages, and costs. During the proceedings, the defendants filed documents, including Batch Manufacturing Records (BMRs) and export records, showing their process for producing Alpha Yohimbine with over 90% purity. The plaintiff initially believed these documents indicated use of Rauwolfia vomitoria (a different species), which he claimed would not infringe his patent focused on Rauwolfia canescens/tetraphylla. The plaintiff's own expert report, filed earlier, analyzed the defendants' process and concluded it was "absolutely dissimilar" to the patented process. The defendants maintained they used Rauwolfia tetraphylla (covered under the plaintiff's patent claims) alongside Rauwolfia vomitoria, had regulatory licenses since 2014, and had been exporting the product commercially for years without infringement.

Procedural Background

The suit was instituted as CS(COMM) 672/2022, with a counter-claim and various interim applications. After the defendants filed their written statement and documents, the plaintiff filed an affidavit dated 21.07.2025 stating that the defendants' documents confirmed use of Rauwolfia vomitoria, removing the cause of action for infringement. The plaintiff sought to withdraw the suit under Order XXIII Rule 1(3)(b) of the CPC, requesting liberty to file a fresh suit if the defendants later used Rauwolfia canescens/tetraphylla. The defendants opposed conditional withdrawal, arguing no fresh cause of action could arise since the patent protects a process, not a specific raw material species, and the plaintiff's expert had already cleared their process of similarity. They sought dismissal of the suit for lack of cause of action and imposition of exemplary costs for frivolous litigation. Arguments were heard, judgment reserved on 11.02.2026, and delivered on 17.02.2026.

Reasoning and Decision of Court

Justice Tushar Rao Gedela rejected the plaintiff's request for conditional withdrawal under Order XXIII Rule 1(3)(b) CPC. The Court observed that the patent protects a specific process for extracting Alpha Yohimbine with high purity from Rauwolfia species, not the raw material itself. Distinguishing infringement based solely on the species of Rauwolfia used was illogical, as the cause of action for infringement arises from using a similar process, regardless of minor variations in raw material. The defendants' documents, including BMRs, showed use of Rauwolfia tetraphylla, yet the plaintiff's own expert report confirmed the processes were dissimilar, negating infringement. The Court held that the plaintiff could not approbate and reprobate—first alleging infringement from use of Rauwolfia canescens/tetraphylla, then claiming no cause of action upon discovering Rauwolfia vomitoria, while seeking to reserve rights for future claims on the same species. Such a conditional withdrawal was impermissible, as what cannot be achieved directly cannot be done indirectly. No formal defect or sufficient grounds existed for liberty to file afresh. Since the suit lacked merit from the outset, particularly after the expert report in 2023, the Court imposed costs of Rs. 50,000 on the plaintiff, payable within four weeks, for dragging the defendants into unnecessary litigation. The suit was not dismissed outright but listed for further proceedings on 08.07.2026.

Point of Law Settled in the Case

This judgment clarifies that in patent infringement suits, withdrawal with liberty to file a fresh suit under Order XXIII Rule 1(3)(b) CPC requires demonstration of formal defect or sufficient grounds, and courts will deny such permission where the plaintiff seeks to preserve a future claim on the same cause of action after realizing the original claim lacks merit. A plaintiff cannot create artificial distinctions (such as raw material species) to justify conditional withdrawal when the patent covers a process applicable across species variations. When a plaintiff's own expert evidence negates infringement and the suit appears frivolous or unsustainable, courts may impose exemplary costs on the plaintiff under Order XXIII Rule 4(b) CPC to deter abuse of process and compensate the defendant for unwarranted litigation.

Case Detail

Title: Pawan Kumar Goel v. Dr. Dhan Singh & Anr.

Date of Order: 17 February 2026

Case Number: CS(COMM) 672/2022, CC(COMM) 16/2023 & I.A. 13948/2023

Neutral Citation: 2026:DHC:1333 (based on standard Delhi High Court neutral citation format for 2026 judgments)

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Hon'ble Mr. Justice Tushar Rao Gedela

Disclaimer: Readers are advised not to treat this as substitute for legal advice as it 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:

Delhi High Court Rejects Conditional Withdrawal in Patent Infringement Suit, Imposes Costs for Frivolous Litigation

No Liberty to File Fresh Suit: Delhi HC Denies Plaintiff’s Attempt to Withdraw Patent Case Conditionally

Patent Process Infringement Claim Fails – Delhi High Court Awards Exemplary Costs to Defendant

When Plaintiff’s Own Expert Clears Defendant: Delhi HC Imposes Costs in Patent Suit Withdrawal Bid

Suggested Tags: #PatentInfringement #DelhiHighCourt #OrderXXIIICPC #WithdrawalOfSuit #ExemplaryCosts #AlphaYohimbine #Rauwolfia #IPLitigation #PatentLawIndia #FrivolousLitigation

Headnote

Suit for permanent injunction alleging infringement of process patent IN 369150 for extraction of Alpha Yohimbine >90% purity from Rauwolfia canescens/tetraphylla — Plaintiff seeks withdrawal under Order XXIII Rule 1(3)(b) CPC with liberty to file fresh suit, claiming defendants use Rauwolfia vomitoria removing cause of action — Court holds patent protects process, not raw material species; distinction untenable — Plaintiff's expert report confirms defendant's process dissimilar, negating infringement — Conditional withdrawal denied as no sufficient grounds; what cannot be done directly cannot be done indirectly — Exemplary costs of Rs.50,000 imposed on plaintiff for unnecessary litigation — Suit listed for further hearing.

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**Brief Summary**

Pawan Kumar Goel, owner of Indian Patent No. 369150 for a process to extract Alpha Yohimbine with over 90% purity from Rauwolfia canescens/tetraphylla, filed a suit claiming Dr. Dhan Singh and another were infringing it by using the same or similar process to make and export the compound. During the case, the defendants filed documents like manufacturing records showing their process and raw materials. The plaintiff then filed an affidavit stating these documents showed use of Rauwolfia vomitoria (a different plant), meaning no infringement occurred, and asked to withdraw the suit with permission to file a fresh one later if the defendants used Rauwolfia canescens/tetraphylla. The defendants opposed this conditional withdrawal, arguing their process was different as confirmed by the plaintiff's own expert report, they had used Rauwolfia tetraphylla for years with valid licenses, and the suit lacked any real basis for infringement. The Court rejected the conditional withdrawal, holding that the patent protects the extraction process itself, not a specific plant species, so distinguishing infringement based only on the plant used made no sense. Since the plaintiff's expert had already found the processes dissimilar and the suit appeared baseless, permission to file afresh was denied. Instead, the Court imposed costs of Rs. 50,000 on the plaintiff for forcing unnecessary litigation on the defendants, and listed the matter for further hearing.

**Points of Law Settled**

- A plaintiff cannot obtain conditional withdrawal with liberty to file a fresh suit on the same cause of action under Order XXIII Rule 1(3)(b) CPC merely to preserve a future claim when the original suit lacks merit or when the plaintiff seeks to create artificial distinctions (such as raw material species) that do not align with the scope of the patent, which protects a process and not a particular raw material (Paras 14–19).

- In patent infringement suits, the cause of action arises from use of a similar or identical process, and minor variations in raw material do not negate infringement or create a separate future cause of action justifying conditional withdrawal (Paras 15–16).

- When a plaintiff's own expert report concludes the defendant's process is dissimilar and negates infringement, and the plaintiff persists with the suit before seeking withdrawal, the Court may refuse permission under Order XXIII Rule 1(3)(b) CPC and impose exemplary costs on the plaintiff under Order XXIII Rule 4(b) CPC to compensate the defendant for being dragged into frivolous or avoidable litigation (Paras 17, 20).

- A plaintiff cannot approbate and reprobate by first alleging infringement based on use of a particular raw material and later claiming no cause of action upon discovering a different raw material, while seeking to reserve rights for the same material in future (Para 16).

**Case Title:** Pawan Kumar Goel Vs. Dr. Dhan Singh & Anr.

**Order Date:** 17 February 2026

**Case Number:** CS(COMM) 672/2022, CC(COMM) 16/2023 & I.A. 13948/2023

**Neutral Citation:** 2026:DHC:1333

**Name of Court:** High Court of Delhi

**Name of Judge:** Hon’ble Mr. Justice Tushar Rao Gedela

**Disclaimer:** Readers are advised not to treat this as substitute for legal advice as it may contain errors in perception, interpretation, and presentation

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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Yashasvi Havelia Vs. Prabhtej Bhatia

Introduction: In a clear and practical ruling, the Delhi High Court has once again reinforced that trademarks which are registered but never used in the market cannot be allowed to block genuine businesses. The Court removed the mark ‘BANDOOK’ from the Register in Class 33 because the registered owner had not used it for more than five years. This judgment protects honest traders who want to use a mark and sends a strong signal that the trademark register must remain clean and reflect actual commercial use.

Factual Background: Yashasvi Havelia is actively engaged in the beverage business. The petitioner had already secured registration of the trademark ‘BANDOOK’ in Class 32 for beer and non-alcoholic drinks. When the petitioner decided to expand into alcoholic beverages (excluding beer) and applied for registration in Class 33, a search revealed an existing registration of the identical mark ‘BANDOOK’ in Class 33 in the name of Prabhtej Bhatia, trading as Raipur Bottling Company. The petitioner claimed that the respondent had never used the mark for any alcoholic beverages since its registration in 2018 and had no genuine intention to use it.

Procedural Background: The petitioner filed a rectification petition under Sections 47 and 57 of the Trade Marks Act, 1999, seeking removal of the impugned registration on the ground of non-use. The petition was duly served on the respondent. Despite service, the respondent neither appeared nor filed any reply. The Registrar of Trade Marks was impleaded as Respondent No.2 and appeared through counsel but raised no opposition. The matter proceeded ex parte against Respondent No.1. After hearing the petitioner, the Court delivered its judgment on 22 January 2026, which contained a typographical error in the operative paragraph. This error was corrected by a subsequent order dated 10 February 2026 under Section 152 CPC, with the consent of the Registrar.

Reasoning and Decision of Court: Justice Jyoti Singh observed that the respondent’s complete silence and failure to file any reply meant that all allegations made in the petition stood admitted. The petitioner had clearly pleaded that the mark had not been used for over five years, supported by investigations showing no excise licences, no manufacturing approvals, no brand registrations, and no commercial activity under the mark. The Court held that the petitioner is a “person aggrieved” because it already holds registration of the identical mark in Class 32 and has a pending application in Class 33. The continued presence of the unused registration was blocking the petitioner’s legitimate business expansion.

Placing reliance on consistent precedents of the Delhi High Court, the judge ruled that once non-use is pleaded and not specifically denied, the allegation is deemed admitted and the mark becomes liable for removal under Section 47(1)(b) of the Act. The Court found that the respondent had no bona fide intention to use the mark and had merely squatted on the registration. Accordingly, the petition was allowed and the Trade Marks Registry was directed to remove the mark ‘BANDOOK’ under Registration No.3762319 in Class 33 from the Register and rectify the records to maintain its purity.

Point of Law Settled in the Case: This judgment settles that when a rectification petition pleads non-use of a registered trademark for the statutory period and the registered proprietor does not appear or specifically deny the allegation, the plea of non-use is deemed admitted and the mark is liable to be removed under Section 47(1)(b) of the Trade Marks Act, 1999. It also reaffirms that a person who has registered or applied for the same or similar mark in a related class and whose business interests are affected is a “person aggrieved” entitled to maintain such a petition. The ruling further clarifies that mere registration without genuine commercial use does not entitle the proprietor to block others, and the Register must be kept free of dead or unused marks.

Case Title: Yashasvi Havelia Vs. Prabhtej Bhatia and Anr.

Date of Order: 22 January 2026
Case Number: C.O. (COMM.IPD-TM) 166/2025
Neutral Citation: 2026:DHC:884
Name of Court: High Court of Delhi
Name of Judge: Hon'ble Justice Jyoti Singh

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it 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 the Article

Delhi High Court Removes Unused ‘BANDOOK’ Trademark for Non-Use
Squatting on Trademark Register No Longer Works: Delhi HC Ruling
Non-Use for Five Years Leads to Removal of ‘BANDOOK’ Mark
Genuine Business Interest Prevails: Rectification Petition Allowed

Suitable Tags

Trademark Rectification, Section 47 Trade Marks Act, Non-Use of Trademark, Delhi High Court Judgment, Person Aggrieved, Trademark Squatting, Bandook Trademark, IP Law India, Trademark Removal, Clean Register

Headnote of Article

The Delhi High Court allowed a rectification petition and directed removal of the trademark ‘BANDOOK’ in Class 33 on the ground of non-use for more than five years. The Court held that the petitioner, being the registered proprietor of the identical mark in Class 32 and having a pending application in Class 33, is a person aggrieved. Since the respondent failed to contest the petition or deny the allegations of non-use, the averments were deemed admitted, leading to removal of the mark to maintain purity of the Register.

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Yashasvi Havelia, who is already the registered owner of the trademark BANDOOK for beer and non-alcoholic beverages, applied for the same mark for alcoholic beverages excluding beer and found an identical registration standing in the name of Prabhtej Bhatia. Claiming the respondent had never used the mark since registration and had no intention to use it, the petitioner filed a rectification petition for its removal. The respondent was duly served but neither appeared nor filed any reply, so the matter proceeded ex parte. The court held that the clear allegations of non-use stood fully admitted due to absence of any denial and that the petitioner was a person aggrieved because the unused mark was blocking its legitimate business expansion. Finding no genuine commercial use, the court allowed the petition and directed the Trade Marks Registry to remove the mark from the Register.

Law settled in the case

When a rectification petition pleads non-use of a registered trademark and the registered proprietor fails to appear or specifically deny the allegation, the plea of non-use is deemed admitted and the mark is liable to be removed.

Case Title: Yashasvi Havelia Vs. Prabhtej Bhatia:22.01.2026:C.O. (COMM.IPD-TM) 166/2025:2026:DHC:884: Hon'ble Justice Jyoti Singh

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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Monday, February 16, 2026

Oswaal Books and Learnings Pvt.Ltd. Vs The Registrar of Trade Marks

Introduction: Delhi High Court has allowed the registration of the mark “ONE FOR ALL” for educational books and related publications. The decision highlights how courts should evaluate everyday suggestive marks when they are used as trademarks. Rather than treating common words as automatically unprotectable, the court examined whether the suggestive marks truly describes the product or merely suggests an idea in the minds of buyers. This judgment is particularly important for businesses in the education sector, where creative slogans help publishers stand out in a crowded market. It reassures companies that a well-chosen tagline can function as a source identifier even if the words themselves are simple and familiar.

Factual Background: Oswaal Books and Learnings Private Limited, a well-known publisher of educational materials, started using the expression “ONE FOR ALL” for its books and academic resources from August 2020. The company chose the phrase to convey that its publications serve as a complete solution for students preparing for various school boards and competitive examinations. In October 2020, Oswaal filed an application to register “ONE FOR ALL” as a trademark in Class 16, which covers printed books and paper goods. The company believed the mark would help customers instantly recognise its products and distinguish them from those of other publishers.

Procedural Background: The Trade Marks Registry examined the application and refused registration, stating that the mark lacked distinctiveness and was a common phrase that anyone should be free to use. Oswaal challenged this refusal before the Delhi High Court through a statutory appeal. A single judge heard the matter and upheld the refusal, observing that “ONE FOR ALL” was a laudatory expression suggesting the books were a universal solution and that the company had not proved the mark had acquired a special meaning among buyers. Feeling aggrieved, Oswaal filed an intra-court appeal before a division bench of the High Court. After hearing detailed arguments from senior counsel, the division bench delivered its judgment on 10 February 2026.

Reasoning and Decision of Court: The division bench carefully studied the mark in the specific context of educational books. The judges noted that “ONE FOR ALL” does not immediately tell a buyer anything about the physical nature, quality, or content of a book. A book is a tangible printed item, and the phrase simply suggests broad coverage or completeness rather than describing any particular feature of the book itself. The court observed that the connection between the mark and the goods is not direct; it requires a moment of thought. Therefore, the mark is suggestive rather than descriptive.

The bench respectfully differed from the single judge’s view that the phrase was laudatory and descriptive in the education field. It emphasised that the test is not whether the words are common in English but whether they describe the goods in question. Since no similar mark existed on the register in the relevant class and the Registry itself had raised no objection about other traders using the same expression, the court found no reason to deny protection. The judges also clarified that the mark need not be proved to have acquired secondary meaning because it already possessed enough distinctiveness on its own in the context of books.

Ultimately, the division bench set aside both the Registrar’s order and the single judge’s judgment. It restored the trademark application to its original position and directed the Registry to proceed with that stage . The appeal was allowed without any order on costs.

Point of Law Settled in the Case: This judgment settles an important principle: when deciding whether a common phrase or slogan can be registered as a trademark, courts must assess it in relation to the specific goods or services and not in isolation. A phrase that appears ordinary may still be protectable if it does not directly describe the character or quality of the product and only suggests an idea. The ruling reinforces that the imagination test remains key — if linking the mark to the goods requires even a slight mental effort, the mark is suggestive and eligible for registration. It also confirms that slogans and taglines can function as independent source identifiers in today’s market, especially in creative industries like publishing. Businesses can now take greater comfort that thoughtful, non-descriptive slogans will receive trademark protection without needing to prove long years of exclusive use.

Case Title: Oswaal Books and Learnings Private Limited Vs The Registrar of Trade Marks Date of Order: 10 February 2026 Case Number: LPA 571/2025 Neutral Citation: 2026:DHC:1249-DB Name of Court: High Court of Delhi Name of Hon'ble Judges: Justice C. Hari Shankar and Justice Om Prakash Shukla

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it 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 the Article

Delhi High Court Opens Door for “One For All” Trademark in Education Sector
Suggestive Slogans Win Protection: Key Takeaways from Oswaal Books Trademark Case
When Common Words Become Trademarks – Delhi High Court Explains the Law
Victory for Publishers: “One For All” Allowed as Registrable Trademark

Suitable Tags Trademark Registration, Delhi High Court Judgment, Suggestive Marks, Distinctiveness in Trademarks, Educational Publishing, Trade Marks Act, Slogan Trademark, One For All Case, IP Law India, Trademark Appeal

Headnote of Article In a landmark ruling, the Delhi High Court allowed registration of the trademark “ONE FOR ALL” for educational books, holding that the phrase is suggestive rather than descriptive when used in Class 16. The division bench clarified that common expressions can be protected if they do not directly describe the goods and possess sufficient distinctiveness in context, thereby providing valuable guidance for businesses seeking trademark protection for creative slogans.

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Oswaal Books adopted the mark “ONE FOR ALL” for its educational publications and sought its registration for printed books. The Registrar refused registration calling the phrase common and non-distinctive. The single judge upheld the refusal holding it descriptive and lacking secondary meaning.

In appeal, the division bench ruled that the mark has no direct or immediate connection with books, merely suggests completeness, and is suggestive rather than descriptive. It is therefore inherently distinctive and registrable without proof of acquired distinctiveness. The court set aside both the Registrar’s order and the single judge’s judgment and directed the application to proceed for registration.

Law settled in the case

Common English phrases and slogans can be registered as trademarks if they are suggestive and do not directly describe the character or quality of the goods. Paras 31-36.

Distinctiveness of a mark must be judged in the specific context of the goods or services and not in isolation.

If any mental effort or imagination is required to connect the mark with the goods, the mark is suggestive and eligible for registration.

Case Title: Oswaal Books and Learnings Vs The Registrar of Trade Marks: 10.02.2026:LPA 571/2025:

2026:DHC:1249-DB:Justice C. Hari Shankar and Justice Om Prakash Shukla

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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Chacha Saree Bazar Pvt. Ltd.Vs Chacha Cloth House

Introduction: In the bustling world of Indian retail, where family-style names often appear in shop signs, a recent ruling from the Delhi High Court brings welcome clarity to how trademarks work for everyday words. The case involved two businesses selling sarees and garments under names that both featured the word "Chacha". While one side had official registration, the other did not. The lower court had refused protection, calling the word too common. The High Court stepped in and reversed that view, explaining why even familiar words can deserve legal shield when used cleverly in a specific business. This decision reminds traders that brand identity matters and courts will step up to prevent customer confusion in competitive markets like clothing.

Factual Background: A Delhi-based company ran a well-known store in Sarojini Nagar Market, offering sarees, lehengas, and similar garments under registered brand names that prominently included "Chacha". These marks had been officially registered years earlier for textiles and clothing. Across the border in Haryana, another trader operated a similar shop in Yamuna Nagar, using the name "Chacha Cloth House" for exactly the same type of goods. The Haryana trader had no registration but had applied for one. The Delhi company noticed the similarity and felt customers might mix up the two shops, especially since both used "Chacha" as the eye-catching part of their branding. They approached the court seeking to stop the Haryana trader from using any version of "Chacha" that could create confusion.

Procedural Background: The Delhi company filed a regular suit for trademark infringement and also asked for an immediate temporary order to halt the rival's use while the case continued. The commercial court first granted a short-term stop order without hearing the other side. Later, after full arguments, the same court changed its mind and removed the stop order. It reasoned that "Chacha" simply means "uncle" in common speech, so no one could claim it as their own, and there was no proof that the word had become specially linked only to the Delhi shop in customers' minds. The court also noted the shops were in different cities and saw no immediate risk of mix-up. Feeling this was unfair, the Delhi company appealed to the High Court, where senior lawyers presented detailed arguments on both sides through oral hearings and written notes.

Reasoning and Decision of Court: The High Court carefully reviewed the entire matter and found the lower court's approach mistaken on basic principles. Judges explained that whether a word like "Chacha" can be protected depends on the kind of goods it is used for, not on its meaning in daily life. Here, "Chacha" has nothing to do with sarees or clothes – it is not a description of fabric, style, or quality. When attached to garments, the word stands out and helps customers remember one particular shop. The court noted that people shopping for sarees do not think deeply about every part of a shop name; they remember the striking or main word. In both brands, "Chacha" was that main word, while the rest simply described the business (Saree Bazar or Cloth House).

Even though the full names looked somewhat different and the shops were far apart, the judges said this does not remove the risk of confusion. Customers with ordinary memory might recall only the "Chacha" part and assume the Haryana shop was connected to the famous Delhi one, especially when both sold identical items. The court added that businesses often grow and open new outlets, so distance today does not guarantee safety tomorrow. The Haryana trader's own attempt to register a similar name was seen as an admission that the word had value and could be protected.

On the visual style of the logos, the court held that differences in design or colour do not save the situation if the spoken or remembered part sounds alike and creates the same impression. After weighing everything, the High Court set aside the lower court's order, restored the protection, and directed the Haryana trader to stop using "Chacha" or "Chacha Cloth House" for garments until the main suit is decided. The appeal was allowed in favour of the Delhi company.

Point of Law Settled in the Case: This judgment settles an important everyday question in trademark law: common spoken words are not automatically free for anyone to use in business if they have no natural link to the product and help identify one seller. Courts must look at the word in the actual context of the trade. The ruling also clarifies that when comparing two similar brand names, the most noticeable or "dominant" part can be given special attention without breaking the rule that full names must be seen as a whole. Further, simply showing other shops somewhere use the same word is not enough to call it "common property"; there must be real, widespread use that actually affects customers' understanding. At the early stage of a case, official registration itself gives strong initial support for protection. Overall, the decision strengthens the message that honest traders who build a name deserve court help to prevent copycats, even when the name uses an ordinary word in a fresh way.

Case Title: Chacha Saree Bazar Pvt. Ltd.Vs Chacha Cloth House Date of Order: 12 February 2026 Case Number: FAO (COMM) 217/2025 Neutral Citation: 2026 DHC 1296 DB Name of Court: High Court of Delhi Name of Hon'ble Judges: Hon'ble Mr. Justice C. Hari Shankar and Hon'ble Mr. Justice Om Prakash Shukla

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it 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 the Article:

Delhi High Court Shields "Chacha" Brand Name for Sarees – Common Word Gets Trademark Protection
Why "Chacha" Cannot Be Freely Copied in Garment Business: Key Takeaways from Delhi High Court Ruling
From Uncle to Brand Icon: How Delhi High Court Gave "Chacha" Distinct Identity in Retail Trade
Trademark Lesson for Retailers: Delhi High Court Says Context Matters More Than Dictionary Meaning

Suitable Tags: TrademarkLaw , BrandProtection, Commonword , DelhiHighCourt, SareeBusiness , IntellectualProperty, TrademarkInfringement, ChachaTrademark, RetailLaw, IndianCourts, DistinctiveMarks. common to trade,

Headnote of Article:

Delhi High Court rules that the word "Chacha", though common in daily speech, becomes distinctive when used for sarees and garments. Reversing the lower court, it grants interim injunction against similar use by another trader, clarifying that dominant features drive customer recall and registration presumes protection even for ordinary words in unrelated trades.

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The Delhi High Court Division Bench, in its oral judgment dated February 12, 2026, allowed the appeal FAO(COMM) 217/2025 filed by Chacha Saree Bazar Pvt. Ltd. & Anr., setting aside the order of the learned District Judge (Commercial Court)-01 which had dismissed the appellants' application for interim injunction under Order XXXIX Rules 1 & 2 CPC in their pending suit alleging trademark infringement and passing off against the respondent using the unregistered mark “CHACHA CLOTH HOUSE” for identical goods like sarees, lehengas, suits, and garments.

The appellants hold prior registrations since 1988/2010/2013 for marks including “CHACHA SAREE BAZAR PVT LTD” (word) and “CHACHE DI HATTI” (device) in Classes 24 and 25, operating from a single outlet in Sarojini Nagar Market, New Delhi. The respondent operates in Yamuna Nagar, Haryana, using “CHACHA CLOTH HOUSE” with labels/logos incorporating “CHACHA”.

The Commercial Court dismissed interim relief on the sole ground that “Chacha” (Hindi for uncle) is a generic/commonplace expression over which no monopoly can be claimed. The Division Bench reversed this, holding that distinctiveness must be assessed vis-à-vis the specific goods/services and not in the abstract or based on etymological meaning; while “Chacha” is an everyday word, it has no natural, descriptive, or etymological link to textiles/clothing/garments, rendering its use arbitrary and inherently distinctive in that trade context, capable of distinguishing the appellants' goods.

Given prior registrations under Section 23 of the Trade Marks Act, 1999, long user, identical goods, market perception overlap, and prima facie confusion likelihood, the Court found balance of convenience and irreparable injury favouring the registered proprietors, granting interim injunction restraining the respondent from using “CHACHA CLOTH HOUSE” or any “CHACHA”-incorporating/deceptively similar marks for such goods pending suit, subject to exceptions if honest concurrent use is later proved.

Law Point:

Distinctiveness of a trademark must be evaluated in relation to the specific goods or services for which it is used, not in the abstract or based on general/commonplace/etymological meaning.

Commonplace words of ordinary language, when arbitrarily adopted as marks in trades lacking etymological nexus, qualify for protection against infringement/passing off, entitling registered proprietors to prima facie interim restraint on identical/similar marks for identical goods where goodwill, prior registration, and confusion elements are established.

Case Title:Chacha Saree Bazar Pvt. Ltd.Vs Chacha Cloth House:February 12, 2026:FAO(COMM) 217/2025:2026:DHC:1296-DB: Hon'ble Mr. Justice C. Hari Shankar & Hon'ble Mr. Justice Om Prakash Shukla

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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Lotus Herbals Pvt.Ltd. Vs DPKA Universal Consumer Ventures Pvt.Ltd.

Introduction: The beauty and skincare market is crowded, and brand names often borrow from nature. When a new face cleanser named “Lotus Splash” entered the market, Lotus Herbals saw it as a direct threat to their long-established “Lotus” identity. The single judge allowed the use, calling it descriptive. On appeal, the Division Bench of the Delhi High Court took a closer look and reversed that view. This ruling shows how courts protect famous marks even when rivals claim their name is just describing an ingredient.

Factual Background: Lotus Herbals has built a strong reputation over many years selling herbal skincare and beauty products under the “Lotus” name and its variations. The company holds several registrations for the word “Lotus” and logos in classes covering cosmetics. Their products are widely known, heavily advertised, and associated with natural ingredients.

DPKA Universal Consumer Ventures, linked to actress Deepika Padukone, launched a face cleanser under the main brand “82°E”. The product was prominently named “Lotus Splash” and highlighted lotus flower extracts as a key ingredient. Lotus Herbals objected, arguing that the name would confuse customers into thinking the product came from them or was connected to their range.

Procedural Background: Lotus Herbals filed a commercial suit seeking a permanent ban on the use of “Lotus Splash” or any similar name. They also asked for an immediate temporary order to stop sales while the case continued. The single judge heard both sides and refused the temporary order. He held that “Lotus Splash” was merely descriptive because the product actually contains lotus extract, so it fell under legal exceptions allowing honest descriptive use. Feeling this was wrong, Lotus Herbals appealed to the Division Bench. Senior lawyers argued at length on both sides. After detailed consideration, the Division Bench delivered its judgment on 16 February 2026.

Reasoning and Decision of Court: The Division Bench found the single judge’s approach mistaken on key points. They agreed there was clear similarity because “Lotus” is the striking and dominant part of both names. An ordinary shopper seeing “Lotus Splash” could easily link it to the well-known “Lotus” products, especially in the same category of face care items. Initial confusion was likely even if later differences became clear.

The court rejected the claim that “Lotus Splash” was purely descriptive. While lotus extract is an ingredient, the full name was used prominently on bottles, packaging, websites, and advertisements – exactly like a brand name. It was not hidden in small print as a mere description. The respondents were treating “Lotus Splash” as their product identifier, not just explaining contents. The presence of “82°E” at the bottom did not remove the risk of mix-up.

The judges stressed that descriptive use defences apply only when the words are used honestly to describe the product without trying to create a brand impression. Here, the overall commercial impression pointed to trademark use. The court also noted Lotus Herbals’ long prior use and strong reputation, making passing off likely as well.

The Division Bench set aside the single judge’s order. It granted the temporary injunction, stopping the respondents from making, selling, or promoting any product under “Lotus Splash” or any deceptively similar name until the main suit is finally decided. The appeal succeeded in favour of Lotus Herbals.

Point of Law Settled in the Case: This judgment clarifies that Prominent display turns a potentially descriptive phrase into infringing trademark use. Courts will examine the full commercial impression created by how the name is actually used on packaging, marketing, and sales – not just the dictionary meaning. Descriptive defences protect genuine explanations of contents but do not allow a rival to build a brand around a word that belongs to someone else. Established brands with proven goodwill receive strong interim protection to prevent customer confusion and dilution of their reputation.

Case Title: Lotus Herbals Pvt.Ltd. Vs DPKA Universal Consumer Ventures Pvt.Ltd.

Date of Order: 16 February 2026
Case Number: FAO(OS) (COMM) 45/2024
Neutral Citation: 2026 DHC 1300 DB
Name of Court: High Court of Delhi
Name of Hon'ble Judges: Hon'ble Mr. Justice V. Kameswar Rao and Hon'ble Mr. Justice Vinod Kumar

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it 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 Article:

Delhi High Court Stops Deepika Padukone’s Brand from Using ‘Lotus Splash’ – Victory for Lotus Herbals
‘Lotus’ Name Protected: Division Bench Overturns Single Judge in Major Cosmetics Trademark Battle
Why Ingredient Names Cannot Become Rival Brands – Lessons from Lotus Herbals Ruling
Delhi High Court Draws Line on Descriptive Use Defence in Beauty Industry Trademark Dispute

Suitable Tags: #TrademarkInfringement #DelhiHighCourt #LotusHerbals #DeepikaPadukone #BrandProtection #CosmeticsLaw #DescriptiveMarks #IndianIPLaw #CelebrityBrands #IPUpdate

Headnote of Article:

Delhi High Court Division Bench grants interim injunction restraining use of “Lotus Splash” by DPKA Ventures (Deepika Padukone’s brand), holding the mark deceptively similar to Lotus Herbals’ registered “Lotus” family and not saved by descriptive use defence, thereby protecting long-established goodwill in the skincare market.

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Lotus Herbals, a long-established company known for herbal skincare and beauty products under the mark “Lotus”, sued DPKA Universal Consumer Ventures (linked to Deepika Padukone) for launching a face cleanser prominently named “Lotus Splash” under its main brand “82°E”. Lotus Herbals claimed the name would confuse customers and infringe its registered trademarks. The single judge refused interim injunction, holding that “Lotus Splash” was merely descriptive because the product contains lotus extract. On appeal, the Division Bench reversed the order. It found “Lotus” the dominant and memorable part of both names, creating clear likelihood of confusion. The respondents were using the name as a brand identifier on packaging, website and advertisements, not merely describing contents. The descriptive defence did not apply when the term functions as a trademark. The appeal was allowed and interim injunction granted restraining the respondents from using “Lotus Splash” or any deceptively similar name till final decision of the suit.

Law settled in the case

When a common word forming the dominant part of a registered trademark is used prominently as a product name, it constitutes trademark use and can cause deceptive similarity even if an ingredient is present. (Paras 34-35)
The descriptive use defence under Section 30(2)(a) is available only for honest description and does not protect use of the term as a source identifier or brand name. (Para 13 & 33)

Case Title: Lotus Herbals Pvt.Ltd. Vs DPKA Universal Consumer Ventures Pvt.Ltd.: 16.02.2026:FAO(OS) (COMM) 45/2024:2026 DHC 1300 DB: Hon’ble Mr. Justice V. Kameswar Rao and Hon’ble Mr. Justice Vinod Kumar

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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Fornnax Technology Pvt.Ltd. Vs. The Registrar of Copyrights

The Delhi High Court, in a significant ruling delivered on **February 11, 2026**, set aside a common order passed by the Registrar of Copyrights dated January 28, 2026, and remanded multiple connected copyright registration applications back to the Registrar for fresh de novo consideration. The decision addresses critical procedural and substantive issues in the pre-registration scrutiny of artistic works under the Copyright Act, 1957, particularly where opposition arises from competitors in the industrial machinery sector. The appellant, Fornnax Technology Private Limited, sought copyright registration for artistic works consisting of technical drawings or views of components of its secondary shredder machines (notably the "Cutting Chamber Part of Secondary Shredder R-4000 Front View" and related models). The Registrar rejected these applications after entertaining oppositions from respondents (including competitors represented through counsel for R-2 to R-4), primarily on the ground that the works had been industrially applied to more than fifty articles, triggering the bar under Section 15(2) of the Act, and thus could not qualify for copyright protection.

The factual matrix revolves around Fornnax's claim to copyright in original artistic works embodied in engineering drawings or visual representations of shredder components designed for waste processing and recycling machinery. The company asserted that these were pure artistic expressions not intended solely for industrial application beyond limited production. The opposing parties, apparently competitors in the shredder or recycling equipment market, challenged the registrability, producing materials such as PR articles, website "success stories" claiming over 100 installations, and even YouTube/social media videos allegedly showing widespread commercial exploitation of the designs.

Procedurally, the appellant filed applications under Section 45 of the Copyright Act for entry in the Register of Copyrights. The Registrar, invoking powers under Section 45(2) to conduct such inquiry as deemed fit, entertained written oppositions and documents from the respondents, conducted a personal hearing on January 21, 2026, and passed the impugned common rejection order. Aggrieved, Fornnax preferred multiple connected appeals under Section 72 of the Act before the Delhi High Court, which were heard together.

The Court, speaking through Justice Tushar Rao Gedela in an oral judgment, identified two primary infirmities warranting remand. First, the Registrar failed to properly address the appellant's specific objection that the opposing respondents were not "persons interested" as contemplated under Rule 70(9) and (10) of the Copyright Rules, 2013, which govern pre-registration scrutiny and opposition at the application stage. Instead, the Registrar erroneously equated or imported the concept of "person aggrieved" (who can seek rectification or cancellation post-registration under Section 50) into the pre-grant phase, thereby allowing competitors to participate and oppose when their locus standi may be limited to post-grant proceedings. The Court emphasized that these are distinct statutory stages with different standing requirements, and the failure to deal with this objection vitiated the order. Reliance was placed on the appellant's submissions citing the Allahabad High Court in Pramod Sharma vs. State of U.P. (2023 SCC OnLine All 1904) to define "person interested," which remained unaddressed.

Second, the Court found a serious breach of natural justice in the Registrar's reliance on electronic evidence (website claims of over 100 installations, PR materials, YouTube videos, and social media content) to invoke the Section 15(2) bar without furnishing copies to the appellant prior to or during the hearing, and without granting any effective opportunity to rebut the same with counter-evidence. The appellant had specifically asserted production of only 29–34 units for certain models and challenged the admissibility of such electronic material under Section 65B of the Indian Evidence Act (or equivalent provisions under the Bharatiya Sakshya Adhiniyam), pointing out lack of certification/affidavit. These contentions, raised in detailed post-hearing written submissions (particularly paras 16–17), found no engagement in the impugned order. The Court held that assertions and counter-assertions on the quantum of industrial application required adjudication on tangible, admissible evidence, which was absent here.

While noting the appellant's reliance on the Supreme Court's recent pronouncement in Cryogas Equipment (P) Ltd. vs. Inox India Ltd. (2025 SCC OnLine SC 780, para 66) — which clarified that an original artistic work does not lose copyright protection merely because a design derived from it is industrially applied — the High Court did not decide the merits. It clarified that no opinion was expressed on whether the works qualified as artistic works retaining copyright or whether the Section 15(2) bar applied, leaving these for fresh examination.

The Court accordingly quashed the impugned order, remitted the applications for de novo consideration by a different officer, directed that the appellant be permitted to rebut any documents relied upon by the respondents, allowed the respondents to file further materials in support of opposition, and explicitly required the Registrar to record a specific finding on whether opposition by the respondents could be maintained at the pre-registration stage. No costs were imposed.

This decision settles important points of law in copyright registration practice. It reinforces the strict separation between pre-grant inquiry/opposition under Section 45 read with Rule 70 (limited to "persons interested") and post-grant rectification/expungement under Section 50 (available to "persons aggrieved"). Conflating the two concepts is impermissible. It also establishes that any reliance on electronic or documentary evidence adverse to the applicant during inquiry must comply with natural justice — copies must be supplied and rebuttal opportunity afforded — failing which the order becomes unsustainable. Finally, it underscores that the Section 15(2) industrial application bar (loss of copyright after more than fifty reproductions without design registration) requires concrete, rebuttable evidence rather than untested website claims or media content, aligning with the Supreme Court's emphasis in Cryogas on preserving underlying artistic copyright despite industrial derivation.

**Case Details**

**Title**: Fornnax Technology Private Limited vs. The Registrar of Copyrights & Ors. (and connected matters)

**Date of Order**: February 11, 2026

**Case Number**: CA (COMM.IPD-CR) 5/2026, 6/2026, 7/2026 & 8/2026 (with connected I.As.)

**Neutral Citation**: Not available in the provided judgment text (awaiting publication)

**Name of Court**: High Court of Delhi at New Delhi

**Name of Hon'ble Judge**: Hon'ble Mr. Justice Tushar Rao Gedela

**Disclaimer**: Readers are advised not to treat this as substitute for legal advice as it 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 the Article**

1. Delhi High Court Remands Copyright Applications: Strict Adherence to Locus Standi and Natural Justice in Pre-Registration Oppositions

2. Fornnax Technology vs Registrar of Copyrights: High Court Quashes Rejection Order Over Procedural Lapses and Evidence Irregularities

3. Pre-Grant Opposition in Copyright Registration: Delhi High Court Draws Clear Line Between "Person Interested" and "Person Aggrieved"

4. Section 15(2) Bar and Electronic Evidence: Delhi High Court Mandates Fair Opportunity in Copyright Registration Proceedings

**Suggested Tags**

Copyright Registration, Registrar of Copyrights, Section 45 Copyright Act, Section 50 Copyright Act, Section 15(2) Copyright Act, Rule 70 Copyright Rules 2013, Natural Justice in IP Proceedings, Person Interested vs Person Aggrieved, Industrial Application of Artistic Works, Delhi High Court IP Judgment, Fornnax Technology Copyright Case, Cryogas Equipment Precedent

**Headnote**

Delhi High Court sets aside Registrar of Copyrights' rejection of artistic work registration applications on grounds of improper conflation of "person interested" (pre-grant) with "person aggrieved" (post-grant), failure to address locus objections, and violation of natural justice by relying on unshared electronic evidence to invoke Section 15(2) bar; matter remanded for de novo consideration by different officer with directions to permit rebuttal and record finding on maintainability of opposition.

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The appellant sought copyright registration under Section 45 of the Copyright Act, 1957 for artistic works comprising technical drawings/views of components (such as the "Cutting Chamber Part of Secondary Shredder R-4000 Front View") of its secondary shredder machines used in waste processing/recycling. The Registrar entertained oppositions from respondents (competitors), considered their documents including website PR articles claiming over 100 installations, YouTube/social media videos, and rejected the applications on February 28, 2026 (impugned common order), primarily invoking the Section 15(2) bar that copyright ceases after industrial application to more than fifty articles without design registration. Aggrieved, the appellant filed connected appeals under Section 72 before the Delhi High Court.

The Court, in its oral judgment dated February 11, 2026, quashed the impugned order and remanded the applications for de novo consideration by a different officer. It held that the Registrar failed to address the appellant's objection that respondents were not "persons interested" under Rule 70(9) & (10) of the Copyright Rules, 2013 (governing pre-registration inquiry/opposition) and wrongly equated them with "persons aggrieved" under Section 50 (post-registration rectification), conflating distinct statutory stages and allowing impermissible pre-grant participation by competitors.

Law Point:

Pre-registration inquiry under Section 45 read with Rule 70 of Copyright Rules, 2013 permits opposition only by "persons interested"; post-registration rectification/expungement under Section 50 is available to "persons aggrieved" these are distinct stages and concepts that cannot be conflated or substituted (paras 4-7, 15).

Case Title: Fornnax Technology Pvt.Ltd. Vs. The Registrar of Copyrights:11.02.2026:CA (COMM.IPD-CR) 5/2026:2026:DHC:1295: Hon'ble Mr. Justice Tushar Rao Gedela

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

Saturday, February 14, 2026

ADS Agro Industries Pvt. Ltd. Vs. The Registrar of Trade Marks

Introduction : The case revolves around the trademark registration battle for the mark 'TAJPURIYA' in Class 33 for alcoholic beverages, highlighting critical procedural safeguards in trademark examination and adjudication under the Trade Marks Act, 1999. The Delhi High Court's decision in this appeal underscores the imperative that the Registrar of Trade Marks must confine refusals to objections explicitly raised in the Examination Report, thereby upholding principles of natural justice and preventing arbitrary shifts in grounds for refusal. This ruling reinforces that applicants deserve a full and fair opportunity to address all objections, and any deviation renders the order unsustainable, especially when the mark is asserted to be arbitrary and devoid of direct descriptive or geographical linkage to the goods.

Factual Background :ADS Agro Industries Pvt. Ltd., a rapidly expanding liquor conglomerate in India's alcohol beverage sector, is involved in manufacturing, marketing, trading, and selling liquor products. The company honestly and bona fide adopted the trademark 'TAJPURIYA' for alcoholic beverages and preparations for making such beverages, claiming the mark to be arbitrary in relation to the goods and inherently distinctive, with no natural or direct connection to alcohol or the industry.

Procedural Background : On 08.06.2021, the Appellant filed Trademark Application No. 4997781 in Class 33 on a 'proposed to be used' basis for the mark 'TAJPURIYA'. The Registrar issued an Examination Report dated 24.06.2021, raising an objection solely under Section 9(1)(a) of the Trade Marks Act, 1999, on the ground that the mark constituted a geographical name and was thus incapable of distinguishing the goods or services of one person from those of another. The Appellant promptly filed a detailed reply dated 26.06.2021, asserting the mark's arbitrariness, inherent distinctiveness, absence of any geographical connection, and entitlement to registration even if hypothetically treated as having geographical origin, relying inter alia on the Gujarat High Court precedent in Sahkar Seeds Corporation v. Dharti Seeds, 2017 SCC OnLine Guj 2577. Following this, the Registrar issued a hearing notice, conducted a hearing on 03.01.2024, and passed the impugned order dated 29.01.2024 refusing registration under Section 9, but on an entirely new and extraneous ground—that 'Tajpuriya' refers to an indigenous tribe of Nepal (also residing in parts of India such as Bihar, West Bengal, Sikkim, and Darjeeling), where alcohol forms an essential part of religious rituals, rendering the mark devoid of distinctive character.

Reasoning and Decision of Court: The Delhi High Court, presided over by Hon'ble Ms. Justice Jyoti Singh, found substantial merit in the Appellant's challenge under Section 91 of the Act. The Court observed that the impugned order suffered from two fundamental defects. First, the refusal was predicated on a fresh ground (tribal name linked to ritualistic alcohol use) never raised in the Examination Report, thereby denying the Appellant any opportunity to contest or reply to it, which violated procedural requirements under the Act and breached principles of natural justice. Second, the original geographical name objection from the Examination Report was neither reiterated nor addressed in the impugned order, and the Registrar failed to engage with the detailed submissions in the Appellant's reply regarding the mark's arbitrariness, inherent distinctiveness, and high degree of protection for arbitrary marks (even those with alleged geographical connotations). The Court noted that shifting to an extraneous ground without prior notice or consideration of the reply rendered the order wholly illegal and unsustainable. Consequently, the impugned order dated 29.01.2024 was set aside, and the matter was remanded to the Registrar for re-examination of the application from the hearing stage, mandating due consideration of the reply to the Examination Report, grant of a fresh hearing opportunity to the Appellant, and completion of the entire process within two months from the date of the judgment.

Point of Law Settled in the Case :The judgment firmly establishes that the Registrar of Trade Marks is bound to restrict refusal grounds to those explicitly articulated in the Examination Report issued under the Trade Marks Act, 1999. Introducing new or extraneous grounds in the final order without affording the applicant prior notice and an opportunity to respond constitutes a serious procedural irregularity, infringing natural justice principles and statutory procedure. Furthermore, where specific objections are raised and a detailed reply is filed addressing distinctiveness, arbitrariness, or exceptions for arbitrary use, the Registrar is duty-bound to deal with and consider those submissions; failure to do so, coupled with reliance on unheralded grounds, vitiates the refusal order. This ruling strengthens applicant protections in opposition and refusal proceedings by mandating transparency, consistency, and fairness throughout the examination and hearing stages.

Case Title: ADS Agro Industries Pvt. Ltd. Vs. The Registrar of Trade Marks

Date of Order: 3rd February, 2026

Case Number: C.A.(COMM.IPD-TM) 33/2024

Neutral Citation: 2026:DHC:1134

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Hon'ble Ms. Justice Jyoti Singh

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation

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

Thursday, February 12, 2026

7-Eleven International LLC Vs The Deputy Registrar of Trade Marks

Brief Note: The Madras High Court, in a detailed judgment on February 11, 2026, dismissed the appeals filed by 7-Eleven International LLC, a global convenience store chain based in the USA, thereby upholding the 2014 order of the Deputy Registrar of Trade Marks. The ruling affirmed the registration of the trademark "Big Bite" in Class 30 in favor of the Indian company Ravi Foods Private Limited (the substituted third respondent, following assignments from the original applicant Dukes Consumer Care Limited), while rejecting 7-Eleven's competing application and opposition. This decision reinforces the territorial nature of trademark rights under Indian law and clarifies the limited role of international reputation and prior filing dates when no actual use or goodwill has been established in the Indian market.

Introduction: Trademark disputes involving identical or highly similar marks often hinge on the fundamental principles of priority, goodwill, and territoriality. In cross-border conflicts, foreign entities frequently invoke their global reputation, extensive international use, and early filing dates to claim superior rights, especially when a local entity enters the scene later. The present case exemplifies such a clash between a multinational giant and an Indian food products company over the mark "Big Bite" for goods in Class 30, encompassing confectionery, biscuits, bakery items, savoury snacks, and related food products. The Madras High Court delved deeply into whether mere international fame, prior adoption abroad, or an earlier application date in India can override the established prior user status of a domestic party that has continuously used the mark in trade within India. The judgment underscores that Indian trademark law, while recognizing trans-border reputation in exceptional cases, predominantly adheres to the principle of territoriality, requiring concrete evidence of goodwill and reputation spilling over into or being cultivated in the Indian jurisdiction for protection against local prior users.

Factual Background: 7-Eleven International LLC, renowned for operating nearly 80,000 convenience stores worldwide under the "7-Eleven" brand (including some presence in India), claimed to have adopted and continuously used the formative mark "Big Bite" since August 1988, primarily for savoury food items such as hot dogs, pizzas, and potato chips sold in its stores. The company asserted that through extensive global use, promotion, and registrations in multiple jurisdictions (including Classes 29, 30, and 43), the mark had acquired a trans-border reputation that extended to India. To secure statutory rights in India, 7-Eleven filed its earliest application for "Big Bite" on August 16, 1994 (Application No. 636986 in Class 30), which was advertised in the Trade Marks Journal on September 16, 2007.

On the other side, the original applicant (M/s. Dukes Consumer Care Limited, later renamed SWG Consumer Care Limited and eventually assigned to Ravi Foods Private Limited effective January 21, 2025) filed Application No. 1297871 in Class 30 on July 19, 2004, seeking registration of "Big Bite" for chocolates, biscuits, bread, pastry, confectionery, ice creams, spices, and other goods in the class. The mark was advertised on May 15, 2005. Ravi Foods (and its predecessors) claimed continuous, open, and extensive use of the mark in India since October 5, 2004, for various food products. 7-Eleven opposed the Indian application, while the Indian side opposed 7-Eleven's earlier-filed but later-advertised application.

Procedural Background: The oppositions were adjudicated together by the Deputy Registrar of Trade Marks, Chennai, who passed a common order on July 18, 2014. In that order, the Deputy Registrar rejected 7-Eleven's Application No. 636986 (opposed by the Indian side under Opposition No. MAS-720132) and accepted the Indian company's Application No. 1297871 (opposing 7-Eleven's opposition under No. MAS-211161). The Registrar primarily relied on the Supreme Court's decision in Milmet Oftho Industries v. Allergan Inc. (2004) to prioritize the first actual user in India, noting that 7-Eleven had not demonstrated any use or business presence in India under the mark, while the Indian party had established prior and continuous local use.

Aggrieved, 7-Eleven filed two appeals under Section 91 of the Trade Marks Act, 1999: (T)CMA(TM) No. 110 of 2023 challenging the acceptance of the Indian application and (T)CMA(TM) No. 157 of 2023 challenging the rejection of its own application. During the pendency of these appeals, there were substitutions of parties due to corporate changes and assignments, culminating in Ravi Foods Private Limited being arrayed as the third respondent. The appeals were heard and reserved on January 22, 2026, and decided on February 11, 2026.

Reasoning and Decision of Court: The High Court meticulously examined the arguments advanced by both sides. 7-Eleven contended that the Registrar erred by applying a narrow "prior user in India" test, ignoring its prior international adoption since 1988, global registrations, trans-border reputation, and earlier filing date in 1994. It argued that the Indian adoption in 2004 was mala fide, aimed at riding on its international goodwill, and that allowing identical use would cause confusion and association. Reliance was placed on numerous precedents, including N.R. Dongre v. Whirlpool Corporation (emphasizing trans-border reputation), S. Syed Mohideen v. P. Sulochana Bai, Milmet Oftho, and various High Court decisions supporting protection of well-known or spill-over reputation.

The Court, however, rejected these contentions after a thorough analysis. It held that Indian trademark law is fundamentally territorial, and rights are acquired primarily through use in India. Mere availability of the mark on a foreign website or international reputation does not automatically confer goodwill or reputation in India absent evidence of actual spillover or substantial business activity on Indian soil. The Court observed that 7-Eleven had not placed any material showing sales, business, or reputation-building efforts in India under "Big Bite" either at the time of its 1994 application or during opposition proceedings commencing in 2007. The mere filing date, while relevant under Section 11, could not override the established prior use by the Indian party since 2004.

Distinguishing the Milmet Oftho line of cases, the Court clarified that trans-border reputation protection is exceptional and requires clear proof of reputation in India, which was absent here. The mark was not shown to qualify as "well-known" under Section 2(1)(zg) or to warrant protection under Section 11(2) or 11(3) without local goodwill. The Court found no error in the Registrar's reliance on territorial prior use and upheld the impugned order in its entirety, dismissing both appeals without costs.

Point of Law Settled in the Case: This judgment reaffirms and strengthens the territoriality principle in Indian trademark jurisprudence, holding that international reputation and prior foreign use, without corresponding goodwill, reputation, or actual business presence in India, cannot defeat the rights of a prior bona fide user who has continuously used the mark in the Indian market. A foreign applicant's earlier application date alone is insufficient to prevail over a local prior user's established trade use, particularly when no spillover of reputation is proved. The decision clarifies the narrow scope for invoking trans-border reputation under Sections 11(2) and 11(3) of the Trade Marks Act, 1999, emphasizing that concrete evidence of Indian goodwill is essential, and mere global fame or website presence does not suffice.

Case Title: 7 – Eleven International LLC Vs The Deputy Registrar of Trade Marks.

Date of Order: 11.02.2026

Case Number: (T)CMA(TM) Nos.110 & 157 of 2023

Neutral Citation: 2026:MHC:542

Name of Court: High Court of Judicature at Madras

Name of Hon'ble Judge: The Hon'ble Mr. Justice N. Anand Venkatesh

Disclaimer: Readers are advised not to treat this as substitute for legal advice as it 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 the Article**

- Madras High Court Upholds Territoriality: Indian Company Wins "Big Bite" Trademark Battle Against Global Giant 7-Eleven

- International Reputation Insufficient Without Indian Goodwill: Madras HC Rejects 7-Eleven's "Big Bite" Claim in Favour of Local Prior User

- Territorial Principle Prevails: Madras High Court Dismisses 7-Eleven's Appeals Over "Big Bite" Trademark Registration

- "Big Bite" Trademark Dispute: Madras HC Affirms Prior Use in India Over Global Fame and Early Filing

**Suggested Tags**

TrademarkLaw, BigBiteTrademark, 7Eleven, RaviFoods, MadrasHighCourt , TerritorialityPrinciple, TransBorderReputation, PriorUser, Section11, TradeMarksAct, IntellectualProperty, IPLitigation, JusticeNAnandVenkatesh, Class30Trademarks, IndianTrademarkDispute,

**Headnote of Article**

Madras High Court dismisses appeals by 7-Eleven International LLC, upholds Deputy Registrar's 2014 order granting "Big Bite" trademark registration in Class 30 to Ravi Foods Private Limited as prior user in India; holds that international reputation and prior foreign adoption/early filing date cannot override local prior use absent proof of goodwill or spillover reputation in India, reinforcing strict application of territoriality under the Trade Marks Act, 1999.

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In this trademark dispute over the mark "Big Bite" in Class 30 for food products like confectionery, biscuits, savouries and allied items, the appellant 7-Eleven International LLC, a US-based global convenience store chain, claimed prior adoption since 1988 internationally, global registrations, trans-border reputation extending to India, and an earlier Indian application filed on 16.8.1994 (No.636986), while the contesting respondent (originally Dukes Consumer Care Ltd, later assigned to Ravi Foods Private Limited) filed its application on 19.7.2004 (No.1297871) and claimed continuous use in India since 5.10.2004. The Deputy Registrar, vide common order dated 18.7.2014, rejected 7-Eleven's application and opposition, accepting the respondent's application on the ground of prior actual use in India, relying on territoriality and Supreme Court precedent in Milmet Oftho Industries v. Allergan Inc. Aggrieved, 7-Eleven filed appeals under Section 91 of the Trade Marks Act, 1999 before the Madras High Court, which were heard and decided on 11.2.2026, dismissing both appeals and upholding the Registrar's order in toto.

Law settled:

Trademark rights in India are primarily territorial; international reputation and prior foreign use/adoption do not automatically confer goodwill or protection in India absent concrete evidence of actual business, sales, spillover reputation or goodwill generated on Indian soil — mere website presence, global fame or prior application date (without use) cannot override a bona fide prior local user's continuous and extensive trade use in India .

In opposition/registration proceedings, the test of prior user in India prevails over international reputation unless trans-border reputation is clearly proved to have permeated the Indian market with substantial evidence; a foreign applicant's earlier filing date is relevant but not decisive when no use is shown in India by the date of application or opposition commencement .

Case Title: 7 Eleven International LLC Vs. The Deputy Registrar of Trade Marks:11.02.2026:(T)CMA(TM) Nos.110 of 2023 : 2026:MHC:542 : Madras HC:Hon’ble Mr. Justice N. Anand Venkatesh

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation]

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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Tuesday, February 10, 2026

Manu Chaudhary Vs Controller of Patents

The Delhi High Court in a significant ruling has set aside the refusal of a patent application involving an oral herbal pain killer composition derived from Indian biological materials, primarily on the ground of non-submission of approval from the National Biodiversity Authority (NBA) at the time of refusal. The Court emphasized procedural fairness, discretion under Section 15 of the Patents Act, 1970, and the mandatory but timing-flexible requirement of NBA permission under the interplay of the Patents Act and the Biological Diversity Act, 2002.

Introduction: This appeal before the Delhi High Court addresses a recurring challenge in patent prosecution involving traditional knowledge and biological resources from India: the mandatory requirement of prior or pre-grant approval from the National Biodiversity Authority (NBA) when inventions utilize biological material sourced from India. The case highlights the tension between strict compliance with biodiversity access regulations and the practical realities of administrative timelines in government bodies. It also touches upon procedural aspects like representation in hearings and the scope of Controller's discretion to refuse or defer decisions. The ruling promotes a balanced approach, ensuring applicants are not unduly penalized for delays beyond their control while upholding the protective intent of biodiversity laws. This decision is particularly relevant for inventors working in herbal, pharmaceutical, and traditional medicine sectors, where Indian biodiversity forms the basis of many innovations.

Factual Background: The Appellant, Manu Chaudhary, an experienced pharmaceutical researcher with over three decades in antimicrobial resistance, natural products, and drug revival technologies, filed Indian Patent Application No. IN 201711047431 (originally titled under related application 2545/DEL/2010 as "Oral herbal Pain Killer Formulations"). The invention pertains to an oral herbal pain killer composition for peripheral pains, comprising effective amounts of selected herbal components (specific plant parts with defined chemical constituents) in predefined ratios to achieve synergistic pharmacodynamic effects. It also includes a simplified, reproducible process for preparing these compositions while preserving safety, efficacy, and stability. The objective was to offer herbal alternatives to existing pain relief medications with reduced side effects, suitable even for patients with ulcers or other vulnerabilities. The application disclosed use of biological materials from India, triggering NBA approval requirements.

Procedural Background:

The application was filed and First Examination Report (FER) issued observing the claims novel and industrially applicable but raised objections on lack of inventive step (citing prior arts D1-D7), non-patentability under Sections 3(d), 3(e), and 3(p) of the Patents Act, and absence of NBA permission under Section 10(4)(ii)(D). The Appellant responded , amending claims from 1-10 to 1-7 to address issues. A hearing notice limited objections to NBA approval and Section 3(p) (implying other grounds were waived). The Appellant attended the hearing via an authorized representative, filed written submissions explaining technical glitches in Form 3 filing and pending NBA approval (evidenced by an email on intimating NBA acknowledgment). Despite this, the Controller refused the application under Section 15 . NBA approval was eventually granted , post-refusal. The Appellant challenged this refusal via appeal under Section 117A(2), seeking revival.

Reasoning and Decision of Court: The Court identified three refusal grounds: (i) lack of timely NBA approval; (ii) non-patentability under Section 3(p) (mere new use of known herbal medicines without technical advancement); and (iii) improper representation by an unauthorized person at the hearing (contrary to Sections 128 and 132). The Court focused primarily on the NBA issue, holding that while Section 10(4)(ii)(D) mandates disclosure and permission for biological material from India, neither the Patents Act nor the Biological Diversity Act, 2002 (Section 6(1A)) prescribes outright rejection for delayed submission. The relevant provision requires registration/approval before grant, not at filing or hearing stages. Guidelines for Processing Patent Applications relating to Traditional Knowledge and Biological Material (paragraphs 19 and 22) reinforce that patents "should not be granted" without NBA permission, but do not compel refusal if approval is pending and the applicant has applied diligently. The Appellant had applied to NBA, informed the Controller via email with acknowledgment proof before the refusal order, and could not control NBA's processing timeline. The Court found the Controller erred by not deferring the order under discretionary powers in Section 15, which allows requiring amendments/documents and refusing only on failure to comply. Non-submission due to pending approval was not a "failure" attributable to the Applicant. On representation, the Court noted the Controller should have objected and deferred rather than proceeding ex parte. Merits under Section 3(p) were not examined, leaving them open. The appeal was disposed of by setting aside the refusal, remanding for re-examination post-hearing (with proper Patent Agent/Advocate representation), considering NBA approval (no new material except this), and deciding within two months.

Point of Law Settled in the Case: The judgment clarifies that while NBA approval is mandatory for patent grant in cases involving Indian biological resources, absence of approval at examination/hearing stages does not automatically warrant refusal if the applicant has applied timely and informed the Controller of pendency. The Controller must exercise discretion under Section 15 to defer proceedings awaiting approval, rather than refusing mechanically, especially when novelty is acknowledged. This prevents hyper-technical rejections and aligns with the proviso in Section 6 of the Biological Diversity Act allowing post-filing but pre-grant approval. It reinforces procedural fairness in patent prosecution involving biodiversity access obligations.

Case Title:Manu Chaudhary Vs Controller of Patents and Designs

Date of Order:07.02.2026

Case Number:C.A.(COMM.IPD-PAT) 36/2024

Neutral Citation:2026:DHC:1095

Name of Court: High Court of Delhi at New Delhi

Name of Hon'ble Judge:Hon'ble Ms. Justice Jyoti Singh

Disclaimer: Readers are advised not to treat this as substitute for legal advise as it 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:**

1. Delhi High Court Sets Aside Patent Refusal: NBA Approval Pendency Not Ground for Immediate Rejection in Biological Material Cases

2. Balancing Biodiversity Compliance and Patent Prosecution: Delhi HC Remands Herbal Painkiller Application for Re-Examination

3. No Automatic Refusal for Delayed NBA Approval – Landmark Clarity from Delhi High Court in Patents Involving Indian Biological Resources

4. Procedural Fairness in Patent Appeals: Delhi HC Emphasizes Controller's Discretion Under Section 15 When NBA Permission is Awaited

**Suggested Tags:** DelhiHighCourt , PatentsAct1970 , NBAApproval , BiologicalDiversityAct, Section104iiD, Section15 , PatentsAct, HerbalPharmaceuticals, TraditionalKnowledge, PatentAppeal , IPLitigation, BiodiversityAccess, Section3p, InventiveStep, PatentProsecutionIndia,

**Headnote:** Delhi High Court sets aside Controller's refusal of patent application for oral herbal pain killer composition under Section 15 of Patents Act, 1970, holding that pending NBA approval (applied for and acknowledged before refusal) warranted deferral rather than outright rejection; Controller must exercise discretion to await pre-grant NBA permission in biological material cases; matter remanded for fresh examination within two months post-hearing with proper representation; merits under Section 3(p) left open.

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In this appeal under Section 117A(2) of the Patents Act, 1970, Manu Chaudhary challenged the Controller's refusal dated 22.02.2024 of patent application IN 201711047431, which claimed an oral herbal pain killer composition using specific Indian herbal components in predefined ratios for synergistic pharmacodynamic effect along with a reproducible preparation process aimed at reducing side effects compared to conventional analgesics.

The application was filed on 30.12.2017, published in 2019, examined after request in 2021, and FER issued on 22.12.2021 raising objections on inventive step, Sections 3(d), (e), (p), and lack of NBA approval under Section 10(4)(ii)(D). The applicant responded by amending claims, but the hearing notice in 2023 restricted objections to NBA approval and Section 3(p). Despite the applicant informing the Controller via email on 28.12.2023 of pending NBA application (acknowledgement received) and attending hearing through authorized representative, the application was refused under Section 15. NBA approval was eventually granted on 04.07.2024 post-refusal.

The Delhi High Court held that the Controller erred in not deferring the refusal order despite proof of NBA application pendency, as neither the Patents Act nor the Biological Diversity Act, 2002 mandates rejection for delayed submission when the applicant has diligently applied and cannot control NBA timelines; Section 6(1A) requires approval only before grant, and relevant Guidelines (paras 19 & 22) prohibit grant without permission but do not compel pre-hearing rejection.

The Court further found that Section 15 confers discretion to await compliance rather than refuse mechanically, especially when novelty was accepted. Representation by authorized representative was also not fatal without prior objection. Merits under Section 3(p) were not examined. The refusal was set aside, the matter remanded for fresh examination within two months after hearing (with proper Patent Agent/Advocate representation), considering NBA approval (no other new material permitted).

Points of Law Settled:

Absence of NBA approval at the time of examination/hearing does not warrant automatic refusal of a patent application if the applicant has applied for approval in time and informed the Controller of its pendency; the requirement under Section 6(1A) of the Biological Diversity Act, 2002 is mandatory only before grant of patent. (Para 14, 16; read with Paras 9, 10)

The Controller must exercise discretion under Section 15 of the Patents Act, 1970 to defer the final order and await submission of NBA permission when the applicant has taken diligent steps and delay is attributable to NBA processing, rather than mechanically refusing the application. (Para 15, 14)

Guidelines for Processing of Patent Applications relating to Traditional Knowledge and Biological Material (paras 19 & 22) prohibit grant of patent without NBA permission but do not provide for rejection of the application merely because approval is awaited despite proof of application having been made. (Para 14, 7)

Where an applicant attends hearing through an authorized representative instead of a registered Patent Agent/Advocate, the Controller should raise objection and defer hearing to allow compliance rather than proceed and refuse on that ground. (Para 11, implied in 16)

Case Title:Manu Chaudhary Vs Controller of Patents:07.02.2026:C.A.(COMM.IPD-PAT) 36/2024 :2026:DHC:1095:Hon'ble Ms. Justice Jyoti Singh

Disclaimer:Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation

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

#IPUpdate #IPCaselaw #IPCaseLaw #IPLaw #IPRNews #IPIndiaupdate #Trademark #Copyright #DesignLaw #PatentLaw #Law #Legal #IndianIPUpdate #AdvocateAjayAmitabhSuman #IPAdjutor

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IP.ADJUTOR

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