Madras High Court Finds Geetham Restaurants Passed Off As Sangeetha For 17 Months, No Trademark Infringement

In a judgment pronounced on March 25, 2026, Justice Senthilkumar Ramamoorthy observed that the defendants had dishonestly adopted a trade dress identical to the plaintiff's iconic red-and-green color scheme to mislead the public into believing that the famous "Sangeetha" restaurants had simply "metamorphosed" into "Geetham.

The court held that during the period between June 1, 2022 and November 2, 2023, the defendants adopted a trade dress deceptively similar to that of the plaintiff by using the same red-and-green colour combination, creating a misleading impression that the well-known “Sangeetha” restaurants had “metamorphosed” into “Geetham”.

The dispute arose from a franchisor-franchisee relationship between the parties from 2011 until May 31, 2022. In early 2022, the defendants sought permission to shift their Medavakkam outlet due to ongoing Chennai Metro Rail construction. After the request was rejected, the parties agreed to terminate the franchise arrangements.

Following termination, the defendants began operating restaurants under the name “GEETHAM” from the same premises in Chennai, including Velachery, T.Nagar, Thoraipakkam, Medavakkam, OMR and Navalur.

Sangeetha contended that the defendants misrepresented their new business as a continuation of the earlier franchise by operating from the same locations, retaining a similar visual identity, and making public statements such as “only the name has changed” and that customers would experience the “same taste and same team”.

The plaintiff sought a permanent injunction against use of the impugned marks, removal of “Geetham” signages, rendition of accounts, and costs.

In defence, the defendants argued that “GEETHAM” was distinct from “SANGEETHA” and that the plaintiff did not hold a standalone registration for the word “Sangeetha”, relying instead on composite marks such as “SVR Sangeetha”.

Accepting this contention, the Court held that the rival marks were not deceptively similar when viewed as a whole, noting that “Sangeetha” is a common word and that the plaintiff's registrations were composite in nature. The claim for trademark infringement was therefore rejected.

However, the Court found that the defendants' initial adoption of a similar trade dress, combined with their continued operation from the same premises and public representations, amounted to misrepresentation sufficient to establish passing off. The Court observed that the defendants had effectively transitioned the plaintiff's customer base to their own business.

Accordingly, the Court granted a permanent injunction restraining the defendants from using the earlier red-and-green trade dress, but declined to restrain use of the name “GEETHAM” or the modified branding adopted after November 2, 2023 pursuant to court directions.

The Court directed the defendants to render a true statement of accounts for the period between June 1, 2022 and November 2, 2023 and to pay the profits earned during that period to the plaintiff.

The Court also directed the former franchisees to pay Rs 10 lakh as costs to Sangeetha

For Sangeetha Caterers: Senior Advocate K.Sriram for A.S.Kailasam and Associates

For Rasnam Foods Pvt Ltd: Senior Advocate P.S.Raman for A.Ramesh Kumar