Delhi High Court Awards Damages to Tata Sons Pvt. Ltd. in Trademark Battle Against Pressure Cooker Manufacturers
Case Title: Tata Sons Pvt. Ltd. v Mangal Yadav & Anr.
CS(COMM) 666/2019 and I.A. 773/2023
Date of Decision: 25th August 2023
Coram: Justice Prathiba M. Singh
Introduction
The case involves a dispute over the trademark “TATA.” The Plaintiff, TATA Sons Pvt. Ltd., seeks a permanent injunction against the Defendants for infringing registered trademarks and copyrights, passing off, dilution, and tarnishment of trademarks related to the mark “TATA.” The mark “TATA” is highly reputed and well-known, associated with the TATA group of companies founded in 1868.
Factual Background
The case involves a dispute over the trademark ‘TATA’ and its unauthorized use by the defendants, Mangal Yadav and Sanjeev Jain. The plaintiff, TATA Sons Pvt. Ltd., is the principal investor and promoter of the TATA group of companies, seeking relief for infringement of registered trademarks and copyrights, passing off, dilution, and tarnishment of trademarks. The ‘TATA’ mark is well-known and has a history dating back to 1868. The plaintiff alleged that the defendants were manufacturing and selling pressure cookers under the ‘TATA’ mark.
Key Legal Issues
- Whether the Defendants’ use of the “TATA” mark on pressure cookers constitutes trademark infringement and passing off ?
- Whether the Defendants’ use of the “TATA” mark causes dilution and tarnishment of the Plaintiff’s trademark ?
Court’s Analysis and Observation:
The Plaintiff established the well-known nature of the “TATA” mark through various documents, including trademark registrations, news articles, and website references. The Defendants’ manufacturing and selling pressure cookers with the “TATA” mark constitute infringement and passing off. The Defendants’ admission of documents and the seizure of infringing products by the local commissioners strengthen the Plaintiff’s case.
Decision of the Court
Justice Prathiba M. Singh granted summary judgment in favor of the Plaintiff. The Court found that the Defendants’ use of the “TATA” mark on pressure cookers constituted infringement of the Plaintiff’s registered trademarks and passing off. The Court held that the mark “TATA” was well-known and recognized globally, and its use by the Defendants could dilute and tarnish the Plaintiff’s trademark. The Court issued a permanent injunction restraining Defendants from manufacturing, selling, or dealing in pressure cookers bearing the “TATA” mark. Damages and costs were awarded to the Plaintiff against both the Defendants, with Defendant No. 1 being directed to pay Rs. 11 lakhs and Defendant No. 2 to pay Rs. 1 lakh. The infringing stock was ordered to be destroyed in the presence of the Plaintiff’s representative.
Conclusion
The judgment underscores the importance of protecting well-known trademarks from unauthorized use. It highlights the court’s willingness to grant summary judgment when defendants admit infringement or fail to provide valid defenses. The damages awarded emphasize the potential consequences of trademark infringement, including monetary penalties and destruction of infringing goods.
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Written by – Ananya Chaudhary