Delhi HC Upholds Interim Injunction for SACHAMOTI Mark

In a significant judgment concerning intellectual property rights within a long-standing family business dispute, the Delhi High Court has upheld an interim injunction restraining the appellants from using the trademark ‘SACHAMOTI’. The Division Bench, led by Justice V. Kameswar Rao and Justice Vinod Kumar, confirmed that the registered proprietor of a trademark maintains a strong prima facie case for protection, which cannot be lightly unseated by competing claims of prior usage without compelling evidence.

A Family Legacy Turned Legal Conflict

The dispute centers on the brand ‘SACHAMOTI’, used for sago (sabudana) products, and involves various members of the Sabu family. The conflict erupted when the respondent, Rajkumar Sabu, secured formal registration for the trademark and label. The appellants—comprising Kaushalya Devi Sabu, Gopal Sabu, and their company, Sabu Trade Private Limited (STPL)—argued that they were the original adopters and continued users of the brand since 1993, asserting superior rights as "prior users" under Section 34 of the Trade Marks Act, 1999 .

The matter reached the Delhi High Court following appeals against a Single Judge’s order that had previously granted an interim injunction in the respondent’s favor while dismissing the appellants' applications.

The Arguments: Registration vs. Prior Use

The appellants contended that their business history, evidenced by various government documents—including AGMARK certifications from 1993 and tax assessment records—proved they were the true originators. Their counsel, J. Sai Deepak, argued that the respondent’s registration was managed while he acted as a director for the family firm, thereby creating a fiduciary conflict.

Conversely, the respondent, represented by Chander M. Lall, argued that the business of Shiv Trading Co. (STC) was rooted in a 1972 establishment by the family matriarch, Chandrakanta Sabu. The respondent maintained that the brand was officially transferred to him through a family arrangement and that his registrations in 2003 and 2006 were valid exercises of his rights as a proprietor.

Court’s Reasoning and Legal Principles

The High Court’s decision rested on the principle that trademark registration provides a statutory presumption of validity under Section 31 (1) of the Trade Marks Act. Addressing the evidence presented by the appellants, the Court noted that while they produced documents attempting to demonstrate long-term use, the veracity and reliability of such evidence could only be conclusively tested through a full trial.

"The evidence on which the defendants rely cannot, therefore, be said to be so strong as to unseat the presumption of validity available to the ‘SACHAMOTI’ mark as registered in favour of the petitioner," the Court stated.

The Bench emphasized that the appellate court does not reassess materials to substitute its own discretion for that of the trial court, provided the initial order was not "arbitrary, capricious, or perverse."

Key Observations

• On the presumption of validity: "It follows that any use of ‘SACHAMOTI’ or label would amount to infringement in terms of Section 29 /51 of the Act."
• On evidence handling: "Any kind of detailed analysis of the veracity, validity and reliability of the documentary material relied upon by either learned counsel by this Court, at this stage, would be premature."
• On the scope of appellate review: "The appellate court will not reassess the material and seek to reach a conclusion different from the one reached by the court below if the one reached by that court was reasonably possible on the material."

Final Decision and Implications

The High Court ultimately dismissed the appeals, finding no legal error in the Single Judge’s decision to maintain the injunction. The Court clarified that this decision is a prima facie finding based on current pleadings and does not preclude the parties from proving their respective claims during the final adjudication of the suits. By favoring the registered proprietor until trial, the Court reinforces the stability and security afforded to registered marks in Indian business litigation, signaling to parties that evidentiary heavy lifting is required to overcome the statutory protections of a registered trademark.