The court found deliberate undervaluation to evade Commercial Court jurisdiction, constituting abuse of process.
In a significant ruling, the Karnataka High Court, presided over by Justice Ravi V Hosmani, dismissed a trademark infringement suit filed by M/s. Shri Prasanna Anjaneya Agrotech against M.R. Pavan Kumar, citing deliberate undervaluation to avoid the jurisdiction of the Commercial Court. The judgment, dated June 1, 2026, highlights critical issues of forum shopping and the improper valuation of reliefs in intellectual property disputes.
The plaintiff, M/s. Shri Prasanna Anjaneya Agrotech, filed a suit alleging trademark infringement and passing off against the defendant, M.R. Pavan Kumar, claiming the unauthorized use of the trademark 'MR GOLD' which was deceptively similar to their registered trademark 'MRN GOLD'. The plaintiff sought a permanent injunction, rendition of accounts, and other reliefs, initially valuing damages at over Rs. 25 Lakhs in a legal notice but reducing the valuation to Rs. 1,000/- in the plaint.
The court found that this undervaluation was a strategic move to avoid the jurisdiction of the Commercial Courts, as the actual dispute fell under the purview of the Commercial Courts Act, 2015, given the nature and valuation of the claim. Justice Hosmani emphasized that such practices amount to forum shopping, which is an abuse of the legal process.
Furthermore, the court addressed issues of territorial jurisdiction, noting that mere isolated sales or transactions within a jurisdiction do not confer jurisdiction to a court. The plaintiff's attempt to establish jurisdiction in Bengaluru was dismissed as an improper tactic, as both the plaintiff and defendant conducted their primary business in Raichur.
The court also rejected the plaintiff's claim of a continuous cause of action based on ongoing trademark infringement. Justice Hosmani clarified that while trademark infringement may give rise to a continuous cause of action, the plaintiff's suit was barred by limitations given their knowledge of the alleged infringement as early as 2015-2016.
The High Court's decision underscores the necessity for plaintiffs to accurately value claims in intellectual property disputes and to file suits in appropriate jurisdictions. The ruling also highlights the court's unwillingness to tolerate manipulative legal strategies designed to circumvent jurisdictional requirements.
Bottom line:-
Trademark law - Rejection of plaint under Order VII Rule 11 of CPC justified when suit is filed in a Civil Court instead of a Commercial Court by deliberate undervaluation of reliefs to avoid jurisdiction of the Commercial Court - Mere stray sales or isolated transactions are insufficient to confer territorial jurisdiction.
Statutory provision(s): Civil Procedure Code, 1908 Order VII Rule 11, Trade Marks Act, 1999 Section 134, Commercial Courts Act, 2015 Section 12.
M/s. Shri Prasanna Anjaneya Agrotech v. M.R. Pavan Kumar, (Karnataka) : Law Finder Doc id # 2914434
