Delhi High Court Bars Sree Tirumalaa Traders From Using “Lakshmi Srinivasa” Mark & Trade Dress

On 22 June, the Delhi High Court granted an ex-parte ad-interim injunction in favour of Sri Lakshmi Srinivasa Agro Foods and SLS Agro Ventures against Sree Tirumalaa Traders, restraining the use of the mark “LAKSHMI SRINIVASA” and a deceptively similar trade dress in relation to rice products.

Justice Tejas Karia held that a prima facie case of trademark infringement and passing off was made out and allowed the plaintiffs' application for urgent interim protection, while restraining the defendant from using the impugned mark and trade dress during the pendency of the suit. He observed:

“The Defendant's use of the Impugned Mark and the Impugned Trade Dress is prima facie dishonest and nothing but an attempt to ride the goodwill and reputation of the Plaintiffs' Marks so as to cause confusion in the market,”

The plaintiffs, Sri Lakshmi Srinivasa Agro Foods and SLS Agro Ventures, are engaged in the processing, marketing and sale of rice under the “LAKSHMI SRINIVASA” brand since 2003.

They claimed statutory protection over multiple registered marks in Class 30, including “SRI LAKSHMI SRINIVASA,” “LAKSHMI SRINIVASA,” “LAKSHMI SRINIVASA SLS,” and “SLS LAKSHMI SRINIVASA,” all featuring packaging with the image of Lord Lakshmi Srinivasa and a distinctive red trade dress.

They also stated that their trade dress is protected under the Copyright Act, 1957, and that their combined annual turnover under the marks runs into hundreds of crores annually, with Plaintiff No. 1 alone reporting over Rs. 165 crore in turnover for 2018–19.

Further, they alleged that Sree Tirumalaa Traders had slavishly copied their marks and trade dress, merely adding the prefix “LAKSHMI SRINIVASA” while replicating the overall visual identity, including the distinctive red packaging and deity image, with the intent to ride on the plaintiffs' goodwill and reputation.

The Court held that the suit satisfied the test of triple identity, noting that the competing marks were deceptively similar, the goods identical, and the trade channels and consumer base common. It further observed that the plaintiffs, as prior adopters, prior users, and registered proprietors, were entitled to protection.

It also noted that the defendant's adoption of the impugned mark and trade dress created a strong likelihood of confusion among consumers and could wrongly suggest an association or origin where none existed.

Accordingly, the High Court directed the defendant to file its reply to the injunction application within four weeks of service. The matter is listed before the Roster Bench on 27 August 2026.