Court restrains defendants from using "JIO" formative marks on multiple domains, directs suspension of infringing websites, and exempts plaintiff from pre-institution mediation citing urgent relief
In a significant judgment delivered on October 7, 2026, the Delhi High Court, presided over by Mr. Justice Purushaindra Kumar Kaurav, granted urgent interim relief to Reliance Industries Limited ("Reliance"), the proprietor of the well-known registered trademark "JIO." The court restrained the defendants from using the "JIO" mark or any deceptively similar variations in relation to lottery, gaming, payment, and allied services on various domain names and websites.
Reliance filed a commercial suit alleging trademark infringement and passing off against Rahul Meena and others, who were operating websites with domain names such as jiolotteryi.com, jiolotterylogin.com, jiolotterygame.com, jiolottery.club, and jiolottery.store. These websites prominently displayed the "JIO" mark and its variants, which the plaintiff claimed were identical or deceptively similar to their well-known trademark and likely to cause confusion, deception, dilution, and injury to their brand.
The Court examined the objectionable websites and observed that they prima facie satisfied the test of "rogue websites" as laid down in the precedent case of UTV Software Communication Ltd. v. 1337X.To (2019 SCC Online Del 8002). The test emphasized a qualitative approach rather than a quantitative one, focusing on whether the primary purpose of the website was to facilitate infringement. The Court noted that blocking individual URLs would be ineffective since rogue websites could easily change URLs to evade restrictions. Therefore, the Court found it justifiable to suspend the entire domain names involved in the infringement.
Consequently, the Court issued the following directions:
- - Defendant No.1, Rahul Meena, was restrained from registering, operating, maintaining, promoting, or using the impugned "JIO" formative marks or any identical or deceptively similar marks.
- - Domain Name Registrars (Defendants Nos. 2 to 10) were directed to suspend the accounts and websites associated with the infringing domain names until further orders.
- - Defendant No.11, the intermediary operating the "Blogger" platform, was directed to disable access to and take down infringing webpages hosting the unlawful content.
Further, the Court granted Reliance exemption from pre-institution mediation under Section 12A of the Commercial Courts Act, 2015, following the Supreme Court's ruling in Yamini Manohar v. T.K.D. Keerthi (2024), given the urgency and nature of the relief sought.
The judgment also implemented procedural directions for the continuation of the suit, including the issuance of summons to the defendants, timelines for filing written statements and replication, and scheduling of further hearings.
This ruling underscores the judiciary's proactive stance against online trademark infringements and unauthorized use of well-known marks on the internet, particularly in contexts such as lottery and gaming, which may mislead consumers and damage brand reputation. It also highlights the legal recognition of "rogue websites" and the challenges involved in internet-based intellectual property enforcement.
Bottom Line:
Trade Mark - Interim injunction - Use of plaintiff's well-known registered mark "JIO" in domain names/websites relating to lottery, gaming and allied services - Objectionable websites held prima facie to satisfy test of "rogue website" - Defendant restrained from using impugned JIO formative marks - Domain name registrars directed to suspend impugned websites and intermediary directed to take down infringing webpage - Exemption from pre-institution mediation granted as urgent interim relief was sought.
Statutory provision(s):
Commercial Courts Act, 2015 Section 12A, Trade Marks Act, 1999, Code of Civil Procedure, 1908 Order XXXIX Rules 1 and 2
Reliance Industries Limited v. Rahul Meena, (Delhi) : Law Finder Doc Id # 2994158
