Court orders halt on the sale of deceptively similar products by Defendant No. 1 in favor of Plaintiff's 'Bare Anatomy' brand.
In a landmark judgment delivered on December 2, 2025, the Delhi High Court, presided by Justice Tejas Karia, granted interim relief to Onesto Labs Private Limited in a case involving alleged trade dress infringement, passing off, and copyright infringement. The judgment restrains Defendant No. 1, Manishaben Bhaveshbhai Narigara, from manufacturing, selling, or marketing products under the mark 'FOXTEEL', which were found to be deceptively similar to Onesto Labs' 'Bare Anatomy' products.
The case CS(COMM) 1281 of 2025 was filed by Onesto Labs, a company known for its premium personal care products, which alleged that Defendant No. 1 was deliberately imitating its trade dress and packaging. The court observed a deliberate attempt by the defendant to misappropriate the goodwill and reputation of Onesto Labs through identical packaging, advertising, and product visuals, which could lead to market dilution and reputational harm to the plaintiff.
The judgment highlighted the deceptive similarity and likelihood of confusion between the products of the two parties. Onesto Labs claimed that their 'Bare Anatomy' brand, recognized for its innovative formulations and distinctive trade dress, was being copied by Defendant No. 1 in a manner that could mislead consumers. The court found that Defendant No. 1's actions constituted systematic acts of unfair competition and misrepresentation, warranting the interim injunction.
In addition to restraining Defendant No. 1, the court directed Defendant No. 3 to take down infringing listings from its e-commerce platform within 24 hours of receiving notice, further solidifying the protection of Onesto Labs' intellectual property rights. The court emphasized the balance of convenience and irreparable injury in favor of the plaintiff, noting that the continuation of such infringing activities would cause significant harm to Onesto Labs.
The plaintiff's legal team, including Ms. Kripa Pandit and Mr. Christopher Thomas, successfully argued the case, demonstrating the extensive use and consumer recognition of the 'Bare Anatomy' brand. The court acknowledged the plaintiff's investment in marketing and distribution, which had established the brand as a well-known trademark.
This judgment comes as a significant enforcement of intellectual property rights, particularly in the realm of trade dress and packaging, where visual identity plays a crucial role in consumer recognition. It underscores the judiciary's commitment to protecting businesses from unfair competition and ensuring that market players operate within the bounds of legal and ethical conduct.
The case was exempted from pre-institution mediation under Section 12A of the Commercial Courts Act, 2015, due to the urgency of the relief sought, as per the precedent set by the Supreme Court in Yamini Manohar v. T.K.D. Krithi, 2023 SCC Online SC 1382.
The matter is scheduled for further proceedings on March 23, 2026, where compliance with the court's orders will be reviewed.
Bottom Line:
Intellectual Property Law - Plaintiff granted interim relief in a case involving allegations of trade dress infringement, passing off, and copyright infringement, with findings of deceptive similarity, likelihood of confusion, and misrepresentation in the market.
Statutory provision(s): Trade Marks Act, 1999 Sections 2(1)(zg), 29; Copyright Act, 1957 Section 2(c); CPC Order XXXIX Rules 1 & 2; Commercial Courts Act, 2015 Section 12A
