Reliance Industries Ltd. v. Pawan Kumar Gupta & Ors. – Delhi High Court Grants Ex Parte Injunction to Protect ‘RELIANCE’ and ‘JIO’ Marks

Posted On - 23 August, 2025 • By - King Stubb & Kasiva

Introduction

The Delhi High Court’s order in Reliance Industries Ltd. v. Pawan Kumar Gupta & Ors. is a significant ruling on trademark protection for well-known marks in India. The Court granted an ex parte ad interim injunction restraining multiple defendants from infringing Reliance’s ‘RELIANCE’ and ‘JIO’ trademarks and associated artistic works. The case also highlights the obligations of e-commerce platforms in delisting infringing listings and disclosing seller details.

Facts

  • Plaintiff: Reliance Industries Limited (RIL), flagship company of the Reliance Group, operating in diverse sectors including telecom, retail, FMCG, and digital services.
  • Marks Involved:
    • RELIANCE – adopted in the 1960s; recognised as a “well-known mark” by the Supreme Court.
    • JIO – adopted in 2011; recognised as a “well-known mark” by the Bombay High Court.
    • Multiple registrations across classes in India and internationally.
  • Defendants:
    • Defendants 1–21: Manufacturers, distributors, and sellers of FMCG products (poha, wheat flour, pulses, etc.) allegedly infringing the ‘RELIANCE’ and ‘JIO’ marks.
    • Defendants 22–28: Major e-commerce platforms including IndiaMART, Amazon, Flipkart, Meesho, Snapdeal, VyaparTimes, MyDukaan.io.
    • Defendant 29: John Doe / unknown infringer.
  • Cause of Action:
    • June 2025: RIL discovered numerous listings on e-commerce platforms selling infringing products with identical/deceptively similar marks and packaging.
    • Many sellers operated under fictitious identities, making offline enforcement difficult.

Issues

  1. Whether the Defendants’ use of the marks and packaging amounts to trademark infringement, passing off, and copyright infringement.
  2. Whether well-known marks are entitled to stronger judicial protection, especially for FMCG goods sold online.
  3. The extent of responsibility of e-commerce platforms in preventing sale of counterfeit goods.

Arguments

Plaintiff (Reliance Industries Ltd.)

  • The Defendants’ marks and packaging are identical or deceptively similar to RIL’s, incorporating key elements like the flame device, font, colour scheme, and layout.
  • Goods are of the same description (FMCG products), sold via similar channels to overlapping customer bases.
  • Given the fame of ‘RELIANCE’ and ‘JIO’, any confusion could harm both consumer safety and brand reputation.
  • Special caution needed since products like poha target rural and semi-literate consumers who rely heavily on visual brand cues.
  • E-commerce platforms must remove infringing listings and disclose complete seller details.

Defendants

  • At this interim stage, defendants 22, 23, and 25 (platforms) appeared and sought time to file replies; primary sellers (1–21) did not contest before the injunction was granted.

Judgment

Hon’ble Justice Saurabh Banerjee granted an ex parte ad interim injunction, holding:

  • Prima facie infringement: Defendants 1–21 copied RIL’s trademarks and artistic works in near-identical form.
  • Likelihood of confusion: Identical goods, trade channels, and target consumers increased risk of deception.
  • Well-known marks protection: Courts must adopt a stricter approach in protecting famous marks, particularly for consumable goods.
  • E-commerce obligations:
    • Platforms (defendants 22–28) to take down/delist infringing listings in Annexure A.
    • Platforms to disclose seller details including contact info, addresses, bank accounts, and phone numbers.

Key Directions:

  1. Restraint on defendants 1–21 from using ‘RELIANCE’/‘JIO’ or deceptively similar marks in any form.
  2. Restraint on use of infringing packaging/artistic works.
  3. Restraint on use of the marks in domain names, trading names, metatags, keywords, etc.
  4. E-commerce platforms to delist infringing goods and assist in identifying sellers.

Conclusion

The Reliance v. Pawan Kumar Gupta order illustrates the judiciary’s readiness to act swiftly to protect well-known marks in the online marketplace. It sends a clear signal to infringers and e-commerce platforms alike that misuse of famous brands especially for consumable goods will invite immediate judicial intervention. The case also reflects the Court’s awareness of digital-era trademark enforcement challenges and its willingness to impose proactive obligations on online intermediaries.