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2025 Supreme(Online)(Tel) 15169
IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
MOUSHUMI BHATTACHARYA, GADI PRAVEEN KUMAR, JJ
Mr.Venkateshwarlu Guduru – Appellant
Versus
Siddhardha Dev Bathula – Respondent
Commercial Court Appeal|COMCA.No.17 of 2025
For the Appellants/Petitioners: Sri R. Ranganathan
For the Respondents: Sri A. Naveen Kumar
Trade secrets and confidential information must be defined, identified, and particularized for injunctions to be valid and enforceable.
Headnote:(A) Relevant laws include trade secret protection and breach of confidence under the Indian law - Key legal principles include the necessity for specificity in claims of trade secrets and confidentiality. -
Facts of the case:
The appeal arises from a temporary injunction against appellants preventing exploitation of protected information obtained through a past business relationship with plaintiffs. -
Findings of Court:
The court found the injunction vague and lacking material specifics, contrary to trade rights and constitutional guarantees. -
Issues: Key issues included whether confidentiality and trade secrets were adequately defined. -
Ratio Decidendi: The appeal was upheld due to the vagueness of the injunction order and failure to specify the nature of the claims. -
Result: The court directed the Trial Court to reconsider the issues afresh.
| Table of Content |
|---|
| 1. background of the appeal regarding injunction on trade secrets. (Para 1 , 2 , 3) |
| 2. the arguments regarding the overarching nature of the injunction. (Para 4 , 5 , 6 , 7) |
| 3. discussion on the requirements for granting an injunction. (Para 8 , 9 , 10 , 11 , 12) |
| 4. legal reasoning addressing the specifics needed in trade secret claims. (Para 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20) |
| 5. conclusion directing reconsideration of injunction order. (Para 21 , 22 , 23 , 24 , 25) |
THE HON’BLE JUSTICE MOUSHUMI BHATTACHARYA AND THE HON’BLE JUSTICE GADI PRAVEEN KUMAR COMCA.NO.17 OF 2025 Sri P. Raghu Ram, learned Senior Counsel representing Sri R. Ranganathan, learned counsel appearing for the appellants.
Sri A. Venkatesh, learned Senior Counsel representing Sri A. Naveen Kumar, learned counsel appearing for the respondents.
JUDGMENT: (Per Hon’ble Justice Moushumi Bhattacharya)
1. The Commercial Court Appeal arises out of an order dated 03.10.2024 allowing the respondents/plaintiffs’ I.A. granting temporary injunction for restraining the appellants/defendants from commercially exploiting or disseminating the proprietary confidential information or trade secrets of the respondents/plaintiffs from divulging the said confidential information which the defendants have gained access to owing to their past relationship with the plaintiffs.
2. The defendants (the respondents in the I.A. before the Commercial Court) are the appellants before us.
3. By the impugned order, the appellants/defendants were restrained from causing the breach of confidential information through commercial exploitation and dissemination of any proprietary confidential information of the respondents/plaintiffs.
4. The appellants/defendants are aggrieved by the absolute and blanket nature of the restraint.
5. Learned Senior Counsel appearing on behalf of the appellants submits that the impugned order is vague, lacks material particulars and is contrary to the rights of the appellants/defendants from carrying on trade and also their fundamental right to carry on any trade or business as guaranteed under the Constitution of India.
6. Senior Counsel further submits that the defendant No.1 worked with the plaintiff No.2 at the nascent stage of the plaintiff’s business. Senior Counsel submits that the plaintiff No.2 is a much bigger enterprise compared to the defendant No.3 but has unlawfully sought to stop the defendants’ business altogether. It is also submitted that the plaintiffs have failed to particularize the confidential information and trade secrets which form the essential cause of action in the Suit. Senior Counsel further submits that there is no trade secret involved in the manufacturing process of the oil seals and the entire procedure for manufacturing is available in the public domain.
7. Learned Senior Counsel appearing for the respondents/plaintiffs relies on the impugned order to urge that the Advocate Commissioner appointed by the Delhi High Court in an earlier Suit i.e., CS (Comm) No.318 of 2019 (renumbered as COS No.19 of 2022) filed by the plaintiffs found several incriminating materials in the premises of the defendants. The material includes lists of customers, boxes, CDs and mails which would show that the defendant No.1 has used the confidential information and trade secrets of the plaintiffs in an unauthorized manner. Senior Counsel further submits that the defendants have obtained orders from the plaintiffs’ customers by using their association with the plaintiffs.
8. We have considered the submissions made on behalf of the parties.
9. The prayers in the plaint in the Suit (COS No.19 of 2022) filed by the respondents in the present Appeal is for permanent injunction on the defendants (appellants) from breaching confidential information and fiduciary duty, misappropriation of unlawful solicitation of clients, breach of contract, unfair competition damages and delivery up, trade secrets. The prayers in the I.A. filed by the plaintiffs are relevant for o
