Court finds 'Halesaga' mark deceptively similar to 'SAGA', protecting pharmaceutical brand's goodwill and preventing consumer confusion.
In a significant ruling, the Delhi High Court, under the judgment of Mr. Tejas Karia, J., has granted an interim injunction in favor of SAGA Lifesciences Limited against M/s Anaadi Global Co. The judgment, delivered on March 28, 2026, involved the dispute over the use of the trademark 'Halesaga', which the court found to be deceptively similar to SAGA Lifesciences' registered mark 'SAGA'.
The case, titled SAGA Lifesciences Limited v. M/s Anaadi Global Co., centered around the alleged trademark infringement and passing off by Anaadi Global Co., which adopted the mark 'Halesaga' for its pharmaceutical and nutraceutical products. SAGA Lifesciences, an established pharmaceutical company since 1981, claimed that the defendant's mark was deceptively similar to its own, and sought to restrain its use to protect its brand and consumer base.
The court examined the plaintiff's extensive use and goodwill associated with the 'SAGA' mark, which is registered under Class 05 for pharmaceutical and medicinal preparations. The defendant's claim of using 'Halesaga' exclusively for nutraceutical products did not hold, as their application for the mark included a broader category under Class 05, which overlaps with SAGA's registered interests.
In its analysis, the court rejected the defendant's argument about the lack of territorial jurisdiction and the notion that the marks were not deceptively similar. It was concluded that the addition of the prefix 'Hale' was insufficient to differentiate 'Halesaga' from 'SAGA', especially as both marks targeted similar product categories and consumer bases.
The court ruled that the presence of the defendant's products on e-commerce platforms accessible in Delhi was sufficient to establish jurisdiction. Furthermore, the court recognized that the export of SAGA-branded products from India constitutes use under Indian trademark law, reinforcing the plaintiff's claims of infringement and passing off.
Acknowledging the plaintiff's substantial revenue and market presence, the court determined that the use of 'Halesaga' could result in consumer confusion and damage to SAGA Lifesciences' reputation. Consequently, the court issued an interim injunction preventing Anaadi Global Co. from using 'Halesaga' or any mark deceptively similar to 'SAGA' in connection with pharmaceutical and medicinal products during the pendency of the suit.
This ruling underscores the court's commitment to safeguarding intellectual property rights and emphasizes the importance of distinctiveness in trademark usage to prevent market confusion.
Bottom Line:
Trade Mark - Interim injunction granted restraining the Defendants from using the mark 'Halesaga' in respect of pharmaceutical and medicinal preparations under Class 05, as the mark was found to be deceptively similar to the Plaintiff's registered mark 'SAGA'.
Statutory provision(s): Trade Marks Act, 1999 Sections 29(2), 56, Code of Civil Procedure, 1908 Section 20, 151.
SAGA Lifesciences Limited v. M/s Anaadi Global Co., (Delhi) : Law Finder Doc id # 2874488
