Delhi High Court Cracks Down On Counterfeit Law Books, Grants Interim Relief To LexisNexis Against Parth Law House
Delhi High Court Cracks Down On Counterfeit Law Books, Grants Interim Relief To LexisNexis Against Parth Law House
Introduction
The Delhi High Court has granted an ex-parte ad-interim injunction in favour of LexisNexis, restraining Parth Law House and others from printing, distributing, or selling counterfeit copies of its legal textbooks. Justice Jyoti Singh held that the plaintiff had established a prima facie case and that interim protection was warranted pending further proceedings.
Factual Background
LexisNexis, a division of RELX India Pvt Ltd, is engaged in legal and professional publishing in India. The “LexisNexis” trademark is registered in the name of Reed Elsevier Properties Inc.. The suit concerns three prominent legal textbooks: Pollock & Mulla – The Indian Contract & Specific Relief Acts (17th Edition), N.S. Bindra – Interpretation of Statutes (13th Edition) and Mulla – The Code of Civil Procedure (20th Edition). According to the plaintiff, through long, continuous and extensive use, these titles and author names have become uniquely associated with it and enjoy substantial goodwill among students and professionals.
The plaintiff alleged that the defendants were printing, distributing and selling counterfeit textbooks that were near-identical replicas of the originals but of inferior quality. It was contended that the counterfeit books reproduced copyrighted content and registered trademarks, and that distinctions could be identified from the holograms, which could be wiped off by rubbing, inferior printing and binding quality, and non-functional QR codes. Investigation revealed that Parth Law House was retailing the infringing textbooks, while another defendant was engaged in manufacturing and distribution. An unknown infringer was also impleaded as more parties were suspected to be involved.
Procedural Background
LexisNexis instituted a copyright and trademark infringement suit before the Delhi High Court seeking urgent interim relief. Upon hearing Senior Counsel for the plaintiff and examining the documents on record, the Court considered the request for ex-parte ad-interim injunction.
Issues
1. Whether the defendants were prima facie manufacturing and selling counterfeit copies of the plaintiff’s textbooks.
2. Whether such acts constituted copyright and trademark infringement.
3. Whether interim injunctive relief was warranted pending adjudication.
Contentions of the Parties
The plaintiff contended that it had built formidable goodwill and reputation in the market through decades of publication and distribution of authoritative legal texts. It argued that the defendants’ publications were exact replicas of its original works, amounting to infringement of both copyright and trademark rights. The plaintiff emphasised that the counterfeit books were of inferior quality and that the hologram affixed to them could be wiped off easily, demonstrating fraudulent imitation. It further submitted that the defendants’ acts were not only injurious to its commercial reputation but also detrimental to public interest, particularly students and legal professionals who rely on authentic legal materials.
As the matter was heard ex-parte, no submissions were recorded from the defendants at this stage.
Reasoning and Analysis
The Court held that the plaintiff had made out a strong prima facie case for grant of interim protection. Justice Jyoti Singh observed that the documents and material placed on record indicated that the defendants were manufacturing and selling counterfeit copies of the plaintiff’s textbooks.
The Court noted that the inferior quality of printing and binding, along with the defective holograms, supported the plaintiff’s allegations of counterfeiting. It further observed that the plaintiff had established substantial goodwill and reputation in its publications, and that continued circulation of counterfeit copies would cause irreparable harm that could not be adequately compensated in monetary terms. The balance of convenience, therefore, lay in favour of the plaintiff.
Decision
The Court granted an ex-parte ad-interim injunction restraining the defendants, their partners, proprietors, officers, affiliates, servants, agents, representatives and dealers from publishing, printing, distributing, selling or offering for sale any books that are substantial reproductions of the plaintiff’s textbooks, amounting to copyright infringement and tarnishment of reputation. The plaintiff was directed to serve copies of the plaint and supporting documents upon the defendants and file proof of service within two weeks. The matter has been listed for further hearing on February 26, 2026.
In this case the plaintiff was represented by Senior Advocate J. Sai Deepak, Advocates Shoumendu Mukherji, Megha Sharma, Aniruddha Ghosh, Sidhi Pramodh Rayudu and Surabhi Tuli, Advocates.
