Delhi High Court Restrains Use Of 'Liv-22', Protects Himalaya's 'Liv.52' Mark

The Delhi High Court on 29 May granted an ex parte ad interim injunction in favour of Himalaya Global Holdings Ltd, restraining the makers of a liver care product sold under the mark "Liv-22" from manufacturing, selling or advertising the product pending further hearing.

A Bench of Justice Jyoti Singh observed held:

"I am of the view that Plaintiffs have made out a prima facie for grant of ex parte ad interim injunction against the Defendants. Balance of convenience lies in favour of the Plaintiffs and they are likely to suffer irreparable harm in case the interim injunction, as prayed for, is not granted."

Himalaya Global Holdings Ltd submitted that it has continuously used the trademark "Liv.52" since 1955 for its herbal liver care formulation developed for liver function support.

It stated that the product enjoys extensive goodwill and has been recognised in the Limca Book of Records as India's highest-selling herbal drug, with approximately one billion tablets and 13 million syrup bottles sold annually worldwide. The company further relied on trademark registrations dating back to 1957 and stated that sales under the mark crossed Rs. 684.54 crores in FY 2024-25.

The plaintiff alleged that Defendant No. 1, a company incorporated in 2017, had adopted the mark "Liv-22" for identical liver care products sold through the same trade channels and to the same consumer base. It contended that the adoption was deliberate and intended to trade upon the reputation of the "Liv.52" mark.

It further submitted that both defendants were operating in concert, as reflected from their GST registrations, and that neither held any trademark registration for the mark "Liv-22".

Himalaya also relied on the Division Bench judgment of the Delhi High Court in Himalaya Drug Company v. M/s. SBL Limited (2012), wherein the Court held that use of the expression "LIV", even in isolation, amounts to infringement of Himalaya's registered trademark.

After considering the submissions, the Court found that the balance of convenience lay in favour of the plaintiffs and that they had made out a prima facie case for grant of interim protection.

Accordingly, the High Court restrained the defendants and all persons acting on their behalf from dealing in goods bearing the mark "Liv-22" or any mark deceptively similar to "Liv.52" until the next date of hearing.

The matter is listed on 5 October 2026.