Court Vacates Territorial Restraints; Emphasizes Clean Hands Doctrine
In a landmark judgment delivered on July 1, 2026, the Delhi High Court, presided by Justices V. Kameswar Rao and Manmeet Pritam Singh Arora, vacated territorial restraints imposed on More Than Water Private Limited and Nesco Limited in a trademark dispute concerning packaged drinking water trademarks. The judgment criticized both parties for relying on fabricated documents and emphasized the importance of the clean hands doctrine in seeking equitable relief.
The dispute arose when More Than Water Private Limited claimed prior use of the mark 'MORE THAN WATERBOX' and alleged deceptive similarity with Nesco Limited's registered mark 'MY WATER BOX'. The Delhi High Court upheld the decision of the Commercial Court denying an absolute interim injunction, citing More Than Water's failure to establish goodwill and reputation in its mark. The court found the invoices relied upon by More Than Water to be fabricated, undermining their claim of commercial use prior to 2023.
Justice Arora, delivering the judgment, condemned both parties for submitting fabricated invoices and documents. The judgment highlighted the significance of presenting genuine evidence and the consequences of seeking relief with manipulated documents. The court declared that parties seeking equitable relief must approach the court with clean hands, failing which discretionary relief would be refused.
Despite the findings, the Delhi High Court vacated the limited injunction that had restrained both parties from selling their products outside their respective states. The court reasoned that the territorial restraint was unwarranted as no prima facie case of goodwill or reputation was established by More Than Water. However, the court cautioned More Than Water to ensure compliance with applicable laws for sales outside Gujarat.
In a significant directive, the court instructed the Registrar of Trademarks in Mumbai to take note of the restraint issued on Nesco Limited's trademark registration obtained through fabricated documents, ensuring that the registration does not prejudice any third party, including More Than Water.
The judgment serves as a reminder of the judiciary's role in safeguarding ethical conduct and maintaining integrity in legal proceedings. The court's decision underscores the importance of the clean hands doctrine in intellectual property disputes, reinforcing the principle that equitable relief is contingent on the party's honesty and transparency.
Bottom line:-
Intellectual Property - Passing off action - Limited injunction granted restraining parties to sell their respective products within the territories of their respective states vacated in appeal - Appellant failed to prove goodwill and reputation in its mark - Conduct of both parties in relying on fabricated documents criticized - Clean hands doctrine emphasized.
Statutory provision(s): Order XLIII Rule 1 of CPC, Section 13(1) of the Commercial Courts Act 2015, Section 10 of the Delhi High Court Act, 1966, Bureau of Standards Regulations, 2022.
More Than Water Private Limited v. Nesco Limited, (Delhi)(DB) : Law Finder Doc id # 2934099
