Bombay High Court Rejects Rynox Gears' Interim Plea To Injunct Steelite From Using 'RHYNOX' Mark

The Bombay High Court on Tuesday refused interim relief to motorcycle gear company Rynox Gears in its trademark dispute with Steelite India, holding that the firm made false statements on oath and failed to establish a case for either infringement or passing off. Rynox had sought to stop the rival from using the mark “RHYNOX” for helmets.

In an order dated March 17, 2026, Justice Sharmila U. Deshmukh said the pleadings were based on “false statements on oath” and observed that a party seeking equitable relief cannot approach the court without clean hands.

Rynox Gears, a partnership firm set up in 2012, alleged that Steelite India was selling helmets under the mark “RHYNOX”, which it said was deceptively similar to its registered mark “RYNOX”.

According to the plaint, the firm was the prior adopter of the mark and had been manufacturing and marketing motorcycle protective gear, including helmets, since 2012. It argued that use of a phonetically similar mark for similar products was likely to cause confusion among consumers.

The company also claimed that it had issued a cease-and-desist notice in October 2023 and that the rival had taken down its website after receiving the notice but resumed use of the mark in 2024, which led to the suit being filed.

The court noted, however, that both sides hold registered trademarks. Referring to the Trade Marks Act, the Bench said one registered proprietor cannot normally sue another for infringement unless the rival registration is shown to be clearly illegal or obtained by fraud. On the material placed on record, the court found no such case.

The court observed that the defendant had applied for registration after conducting a search of the Trade Marks Registry, and the plaintiff's mark was published thereafter. In these circumstances, the Court held that no relief for infringement could be granted.

The court also found that the plaint contained false statements on oath. The plaintiff had stated that it had been manufacturing and marketing helmets since 2012, but the material on record showed that its business was limited to motorcycle riding gear and accessories such as jackets, gloves, apparel, and luggage.

The Court noted that the plaintiff had no presence in the helmet segment when the defendant commenced use of its mark in 2016–2017.

The Court further found that the plaintiff had wrongly stated that the cease-and-desist notice had been served and that the defendant had taken down its website. The record showed that the notice had been returned unserved. The Court observed that this statement appeared to have been made to explain the delay of nearly one year in filing the suit.

Holding that a party seeking equitable relief must come to court with clean hands, the Bench held that the application deserved dismissal on this ground.

On the claim of passing off, the court held that the plaintiff failed to satisfy the test of goodwill, misrepresentation and damage. The Court noted that the plaintiff had not shown any goodwill in the helmet segment, while the defendant had been selling helmets since 2016–2017.

The bench also observed that the defendant's composite label, which included a rhinoceros device and a stylised depiction of the letter “X”, contained sufficient distinguishing features. A solitary instance of an e-commerce listing was held insufficient to establish likelihood of deception.

In view of these findings, the High Court held that no prima facie case was made out for grant of injunction either for infringement or passing off and dismissed the interim application.