Delhi High Court Holds 2020 Product-Specific Relaxation Does Not Permit ‘SUJATA’ as Corporate Name

Delhi High Court Holds 2020 Product-Specific Relaxation Does Not Permit ‘SUJATA’ as Corporate Name

Introduction

The Delhi High Court has held that a limited relaxation granted in 2020 permitting use of the mark “SUJATA” for specified products does not extend to its use as a corporate or trade name. The Court clarified that the earlier modification merely carved out a narrow product-specific exception and did not dilute the broader injunction restraining use of the mark as part of corporate identity, domain names, or email addresses.

Factual Background

The suit was instituted by Mittal Electronics, the registered proprietor of the “SUJATA” trademark, against Sujata Home Appliances (P) Ltd. On 7 February 2020, the Court had passed an ex parte ad interim injunction restraining the defendant from using the mark “SUJATA” in relation to several products. The injunction, passed in terms of the plaintiff’s prayer clause, specifically extended beyond product branding and restrained use of the mark as part of corporate names, domain names, and email addresses.

Subsequently, on 9 September 2020, the Court relaxed the injunction to a limited extent, allowing Sujata Home Appliances (P) Ltd. to continue manufacturing and selling water filters, water purifiers, and RO systems under the “SUJATA” mark. The present application sought clarification that this relaxation also permitted use of “SUJATA” as the defendant’s corporate and trade name for those specified products.

Procedural Background

The clarification application came up before Justice Tushar Rao Gedela, who examined the scope of the 2020 modification order and whether it displaced the original broader restraint.

The Court also noted that the plaintiff had already initiated contempt proceedings under Order XXXIX Rule 2A CPC in 2021, alleging violation through continued use of “SUJATA” as part of the defendant’s corporate identity.

Issues

1. Whether the 2020 product-specific relaxation permitted use of “SUJATA” as a corporate or trade name.

2. Whether the earlier broader restraint on corporate identity continued to operate despite the limited exception.

3. Whether the defendant’s delayed clarification plea after nearly five years had merit.

Contentions of Parties

The defendant, Sujata Home Appliances (P) Ltd., contended that once it had been permitted to use the “SUJATA” trademark for specific products such as water purifiers and RO systems, the same permission should logically extend to use of the mark as its trade and corporate name for those very products.

The plaintiff, Mittal Electronics, opposed the plea, arguing that the original injunction expressly restrained use of the mark as part of the defendant’s corporate name and that the 2020 order merely created a narrow exception limited to product branding.

Reasoning and Analysis

The High Court rejected the defendant’s attempt to expand the scope of the 2020 relaxation. It held that the September 9, 2020 order was confined strictly to use of the mark on the specified products and could not be interpreted as superseding the wider injunction granted earlier.

The Court emphasized that the 2020 order merely carved out an exception from the original restraint and did not “supplant” the earlier directions, which continued to prohibit use of “SUJATA” as part of the defendant’s corporate or trade identity.

A significant factor weighed by the Court was the nearly five-year delay in seeking clarification. Justice Gedela noted that no plausible explanation had been offered for this prolonged silence, particularly when contempt proceedings had already been initiated in 2021 on the very issue of corporate name usage.

The Court observed that such long inaction itself demonstrated that there was no genuine uncertainty about the meaning of the earlier orders. It inferred that the defendant’s present plea was an afterthought rather than a bona fide clarification request.

The Bench further reiterated that since the original injunction had been passed in terms of the plaintiff’s prayer clause which specifically covered use as corporate name, domain name, and email address the defendant could not now seek to read the limited exception as nullifying those restraints.

Decision

The Delhi High Court held that the limited 2020 relaxation permitting use of “SUJATA” for water filters, water purifiers, and RO systems did not extend to use of the mark as a corporate or trade name. Accordingly, the Court dismissed the application filed by Sujata Home Appliances (P) Ltd., affirming that the broader injunction in favour of Mittal Electronics continued to operate.

In this case the plaintiff was represented by Advocates Manish Biala and Devesh Ratan. Meanwhile the defendant was represented by Advocates Neeraj Grover, Meenakshi Ogra, Tarun Khurana, Samrat S. Kang, Vishnu Gambhir, Chhavi Pande and Anubhav Gupta.