Delhi High Court Declines Interim Relief in ‘NATRAJ’ Trademark Dispute, Says Family Ownership Claims Must Go to Trial

Delhi High Court Declines Interim Relief in ‘NATRAJ’ Trademark Dispute, Says Family Ownership Claims Must Go to Trial

Introduction

The Delhi High Court has refused to grant an interim injunction in a trademark dispute concerning the “NATRAJ” mark used for saffron and edible silver foil, holding that the controversy stems from a family ownership conflict requiring full trial. The Court observed that the dispute is not one involving a stranger infringer, but rather competing claims by members of the same family over ownership and goodwill in the mark, and therefore no prima facie case for exclusive interim protection was made out.

Factual Background

The dispute arose from a commercial suit instituted by Varun Chopra, who sought to restrain his relatives from using the marks “SV NATRAJ”, “SV RAJ”, “RAJNUT”, and “SRI NATRAJ JI”, alleging infringement and passing off of the family’s long-used “NATRAJ” trademark.

The plaintiff claimed that the mark originated from the family concern Raja Traders, established in 1956 and formally registered in 1978, and that his grandfather J.K. Chopra became the sole proprietor after 1980. According to the plaintiff, the exclusive rights in the mark were assigned to him through an assignment deed dated 20 June 2022.

The plaintiff further relied on affidavits allegedly filed by the defendants before the Trade Marks Registry, contending that such documents amounted to acknowledgment of J.K. Chopra’s ownership, thereby estopping the defendants from setting up competing rights.

The defendants, comprising the plaintiff’s uncles and cousins, disputed the exclusivity claim and asserted that the brand, business, and goodwill formed part of joint family rights, relying on a 1971 will and a 2019 family arrangement.

Procedural Background

The plaintiff moved an application seeking interim injunction to restrain the defendants from continuing use of the impugned marks during pendency of the suit.

The matter came up before Justice Tejas Karia, who examined the rival claims, documentary basis, and the nature of the competing marks at the interlocutory stage.

Issues

1. Whether the plaintiff established a prima facie case of exclusive ownership over the “NATRAJ” trademark.

2. Whether the defendants’ use of “SV NATRAJ”, “SV RAJ”, “RAJNUT”, and “SRI NATRAJ JI” creates a likelihood of confusion amounting to infringement or passing off.

3. Whether the balance of convenience and irreparable injury warranted grant of interim injunction in a family ownership dispute.

Contentions of Parties

The plaintiff argued that the “NATRAJ” mark had acquired substantial goodwill and secondary meaning, and that the defendants were estopped from disputing exclusive ownership in view of prior affidavits acknowledging J.K. Chopra’s rights. It was contended that the impugned marks were deceptively similar and likely to cause confusion in the market.

The defendants, on the other hand, contended that the matter was fundamentally a family dispute concerning shared ownership rights in the business and mark, and therefore no one family member could claim exclusivity without trial. They further submitted that “NATRAJ,” being the name of a Hindu deity, could not be monopolised per se, and that the competing marks were sufficiently distinct in overall appearance and commercial impression.

Reasoning and Analysis

The Court first emphasised that the present dispute is not one involving a stranger infringer, but rather a family ownership contest, where each side asserts entitlement to the mark and its associated goodwill. In such circumstances, the core issue is ownership, which necessarily requires final adjudication after trial.

Applying the anti-dissection rule, the Court examined the rival marks and held that marks such as “SV RAJ” and “RAJNUT” are prima facie dissimilar in their visual, phonetic, and structural features, and do not presently create a likelihood of confusion.

As regards marks incorporating “NATRAJ”, the Court noted that the plaintiff himself was not asserting exclusivity over the word per se, and had not placed sufficient material at the interim stage to establish that the composite mark or device had acquired such overwhelming secondary meaning as to justify exclusive protection.

The Court also found that the plaintiff’s claim of exclusive ownership rested upon documents such as the assignment deed and earlier affidavits, which would require detailed evidentiary scrutiny during trial, particularly in light of the defendants’ reliance on the 1971 will and 2019 family arrangement.

On the question of interim relief, the Court held that the balance of convenience did not favour the plaintiff, since restraining the defendants at this stage would seriously disrupt their ongoing family business operations. It further held that any alleged loss suffered by the plaintiff could be adequately compensated by monetary damages, and therefore no case of irreparable injury was made out.

Decision

The Delhi High Court dismissed the application for interim injunction, holding that the dispute involves competing family ownership claims over the “NATRAJ” mark, which can only be conclusively determined after trial. The Court thus declined to grant disruptive interim relief in the absence of a clear prima facie case of exclusive ownership.

In this case the plaintiff was represented by Senior Advocate Apoorv Kurup with Advocates Puneet Yadav, Sourabh Gupta, Akshansh Gupta, Gurjas Varul, Vasudev, and M. Priya Mittal.