Delhi High Court Rejects Godrej's ₹1 Crore Contempt Claim Against Geeken Over Registered Designs

The Delhi High Court on 13 October declined to initiate contempt action against Geeken Seating Collection Private Limited in a design infringement suit filed by Godrej and Boyce Manufacturing Company Limited, holding.

Justice Purushaindra Kumar Kaurav noted that Godrej had failed to establish wilful disobedience of the Court's orders, and observed that “a breach which is inadvertent, or which arises from a bona fide understanding of the scope of the order, does not attract punitive consequences.”

Godrej had sued Geeken over seven registered designs. The Court had restrained Geeken from selling products identical to two designs, while Geeken had undertaken to stop manufacturing products infringing the remaining five designs during their validity.

Subsequently, Godrej alleged that Geeken continued to display the products on its website and that quotations had been provided at its New Delhi and Chandigarh stores in mid-2025.

On 1 August 2025, Geeken attributed the sales to a “communication gap” with its sales staff and described them as inadvertent. The Court cautioned that any further manufacture or sale would be treated as aggravated contempt.

Godrej later relied on a November 2025 invoice, continued website listings and Geeken's failure to file a certified inventory. It sought the detention of Geeken's directors and officers, attachment of its properties and punitive damages of Rs. 1 crore.

The Court held that the undertaking recorded on 6 February 2025 was limited to discontinuing the manufacture of infringing products. It contrasted this with the November 2024 order, which expressly restrained the sale of products corresponding to two designs.

It said that “such a restraint cannot now be read into the undertaking dated 06.02.2025 in contempt proceedings.” It also found Geeken's understanding that the undertaking did not prohibit sales of existing stock to be bona fide, particularly because Geeken had disclosed the sales on the first date of hearing.

Further, the Bench held that its caution of 1 August 2025 operated prospectively and applied only to manufacture or sale after that date. Godrej had not established any such manufacture or sale. It was satisfied that the November 2025 invoice had not been issued at Geeken's instance and observed that continued catalogue listings, by themselves, did not establish manufacture or sale.

Although it expressed displeasure at Geeken's delay in filing the certified inventory, it observed that “disobedience under Order XXXIX Rule 2A of the CPC must be conclusively established, and cannot be presumed or inferred.”

Accordingly, the High Court disposed of both applications, allowing Godrej to raise its damages claim at trial and file a fresh application if it discovered further violations. It clarified that its observations would not affect the merits of the suit.