Delhi High Court Restrains Former Geetanjali Franchisee From Using 'GEETANJALI' Trademarks

The Delhi High Court has granted an ex parte ad-interim injunction restraining a former franchisee of Geetanjali Salon Private Limited from using the trademarks "GEETANJALI" and "GEETANJALI STUDIO".

The court prima facie found that the salon continued to operate under the brand even after its franchise agreement was terminated.

Justice Anup Jairam Bhambhani observed that Geetanjali Salon had made out a prima facie case for interim protection.

"Despite termination of the franchisee agreement by the plaintiff, the defendants are continuing to run their salon in Dhanbad using the plaintiff's trademarks, and are thereby earning revenue based on the plaintiff's goodwill and reputation.", the court observed.

Geetanjali Salon operates more than 140 salons and franchises across India under the marks "GEETANJALI", "GEETANJALI STUDIO" and "GEETANJALI SALON". In July 2024, it entered into a franchise agreement with the operators of a salon in Dhanbad, Jharkhand, granting them a non-exclusive licence to use its registered trademarks.

Geetanjali Salon alleged that the franchisees defaulted on continuing franchise fee payments. It issued a default cure notice in February 2026 and later terminated the franchise agreement through a lawyer's notice, directing them to stop using the GEETANJALI marks.

The company claimed that more than ₹10 lakh remained unpaid and that the salon continued operating under the GEETANJALI name despite the termination. It also alleged that its representative visited the outlet on June 2, 2026, and received an invoice bearing the GEETANJALI marks.

After examining the record, the court observed that both businesses operated in the same trade and catered to the same consumer base.

It held that customers were likely to believe the services were being provided on behalf of Geetanjali Salon, which could harm the company's goodwill and reputation.

"It appears that the parties are in the same or identical trade and business, with a common or identical consumer base; and therefore the likelihood of deception or confusion between their services is likely. It would also appear that an unwary consumer of average intelligence is likely to believe that the services provided by the defendants are being rendered on behalf of the plaintiff, which may likely harm the plaintiff's goodwill and reputation.", the court noted.

The court also observed that the GEETANJALI and GEETANJALI STUDIO trademarks are registered in India and have been in use for a long time. This, it observed, gave rise to a prima facie inference of trademark infringement.

Holding that Geetanjali Salon had established a prima facie case, that the balance of convenience was in its favour, and that it would suffer irreparable harm without interim relief, the court granted an interim injunction.

It restrained the former franchisees and anyone acting on their behalf from using "GEETANJALI", "GEETANJALI STUDIO", or any identical or deceptively similar mark until the next date of hearing.