M/s Sri Lakshmi Srinivasa Agro Foods secures interim relief against Sree Tirumalaa Traders for trademark violation
In a significant ruling, the Delhi High Court has granted an ex-parte ad-interim injunction in favor of M/s Sri Lakshmi Srinivasa Agro Foods, restraining Sree Tirumalaa Traders from using trademarks and trade dress that are deceptively similar to the well-established marks of the plaintiff. The decision was delivered by Justice Tejas Karia on June 22, 2026, emphasizing the protection of intellectual property rights in the competitive agro-food industry.
The case, registered as CS(COMM) 667 of 2026, involved allegations by the plaintiff, M/s Sri Lakshmi Srinivasa Agro Foods, against the defendant, Sree Tirumalaa Traders, for unauthorized use of the trade mark "LAKSHMI SRINIVASA" and associated trade dress. The plaintiff argued that such use was likely to cause confusion among consumers and damage the plaintiff's established goodwill and reputation.
Justice Karia, considering the urgency of the matter, exempted the plaintiff from the requirement of pre-institution mediation under Section 12A of the Commercial Courts Act, 2015. The court cited the Supreme Court's judgment in Yamini Manohar v. T.K.D. Krithi, 2023 SCC Online SC 1382, which allows for such exemptions when urgent interim relief is sought.
The plaintiff successfully demonstrated a prima facie case, showcasing long-standing use and registration of their trademarks, supported by substantial business turnover and market presence. The court found the defendant's use of the impugned mark and trade dress to be prima facie dishonest, aimed at capitalizing on the plaintiff's market reputation. The court applied the "triple identity test," confirming that the marks were deceptively similar, the goods were identical, and the trade channels overlapped.
Justice Karia emphasized that the balance of convenience favored the plaintiff, and irreparable harm would ensue without the injunction. Consequently, the court restrained Sree Tirumalaa Traders and associated entities from manufacturing, selling, or promoting rice using the disputed marks and trade dress.
The decision highlights the judiciary's commitment to safeguarding intellectual property rights and preventing consumer confusion in the marketplace. The matter is scheduled for further proceedings on August 27, 2026.
Bottom line:-
Intellectual Property Law - Grant of ex-parte ad-interim injunction in a case of trademark infringement and passing off - Defendant restrained from using trademarks and trade dress deceptively similar to the Plaintiffs' well-established marks.
Statutory provision(s): Commercial Courts Act, 2015 Section 12A, Civil Procedure Code, 1908 Order XXXIX Rules 1 and 2, Copyright Act, 1957
