No Monopoly Over Word 'Forest' Unless It Has Secondary Meaning: Delhi High Court Refuses To Halt Baby Forest

Holding there can be no monopoly over the word “FOREST” without stringent proof that it has acquired a secondary meaning, the Delhi High Court has refused to grant an interim injunction in favour of the luxury Ayurvedic brand Forest Essentials, allowing a newer entrant, Baby Forest, to continue using 'BABY FOREST' and 'BABY FOREST-SOHAM OF AYUVEDA' marks.

In a judgment pronounced on February 27, 2026, a Division Bench comprising Justice Navin Chawla and Justice Madhu Jain upheld the Single Bench's decision to refuse an interim order of injunction against Baby Forest, finding that the established brand could not claim an exclusive monopoly over the dictionary word “Forest.”

“'FOREST' being a dictionary word, to claim any monopoly over the same, stringent evidence test of having required a secondary meaning in the same would be required from the plaintiff/appellant,” it clarified.

Mountain Valley Springs India Private Limited filed the appeal to challenge a judgment of the Single Bench that refused to grant an interim injunction restraining the respondents from using the marks “BABY FOREST” and “BABY FOREST-SOHAM OF AYUVEDA.”

The appeal challenged a judgment of a learned Single Judge of the Delhi High Court which dismissed the appellant's applications for an interim injunction.

Mountain Valley Springs India Private Limited submitted that it has used the “FOREST ESSENTIALS” mark continuously since 2000, achieving a formidable reputation with annual sales exceeding Rs. 425 crores. The company alleged that Baby Forest Ayurveda had dishonestly rebranded itself from its original corporate name to mimic Forest Essentials' identity and capitalize on its goodwill.

To prove actual confusion, the Forest Essentials presented evidence including Google search predictions that associated the two brands and inquiries from luxury hotel chains like Hyatt and Oberoi asking if the companies were related. The appellant contended that because the products, such as oils, soaps, and lotions, are identical, a higher degree of distinctiveness was required for the respondent's branding.

In response, Baby Forest submitted that “FOREST” is a common dictionary word used throughout the cosmetic and skin care industry to signify that ingredients are organic, herbal, or connected to Ayurveda.

They asserted that as Forest Essentials registration is for the composite mark “FOREST ESSENTIALS,” it cannot legally dissect the mark to claim an exclusive right over a descriptive component. They further argued that it operates in a specialized niche of baby care products, whereas Forest Essentials' primary reputation is for adult products, and that their respective logos, a sapling for the respondent versus a mature tree for the appellant, are visually distinct.

Relying on an earlier Supreme Court precedent, the Court reiterated that the foundational principle of trademark law is the “anti-dissection rule,” which requires marks to be compared in their entirety rather than as individual parts.

The Bench observed that since “FOREST” is a dictionary word, any claim of monopoly requires “stringent evidence” that the term has acquired a secondary meaning exclusively associated with the plaintiff.

Applying the standpoint of an “average purchaser with imperfect recollection,” the Court found that the marks were not deceptively similar, noting that the overall trade dress and layout of the packaging were dissimilar enough to prevent widespread confusion.

“As far as the 'Tree' logo and overall packaging are concerned, we again do not find the same to be sufficient to, at least at this stage where we are to apply the trinity test of good prima facie case, balance of convenience and irreparable harm and injury, to be made out by the appellant for grant of injunction,” the Court remarked.

Accordingly, the court dismissed the appeal and disposed of the pending applications.

The Court concluded by clarifying that its observations are prima facie and will not affect the final adjudication of the suit during trial