Intellectual Property Protection of “Lahori Zeera” : A Case Study of Trademark, Copyright and Design Rights in India

Intellectual Property Protection of “Lahori Zeera” : A Case Study of Trademark, Copyright and Design Rights in India. Intellectual property rights play an important role in protecting the goodwill, reputation, brand identity and distinctive commercial features of consumer products. The litigation surrounding “LAHORI ZEERA”, a non-alcoholic beverage brand marketed by Archian Foods Private Limited, provides a useful contemporary example of the interaction between trademark law, passing off, copyright and registered design protection in India.
The Lahori Zeera disputes are particularly significant because the proprietor's claims were not confined to the use of a brand name. The proceedings involved allegations of trademark infringement, passing off, copyright infringement and piracy of a registered bottle design, together with claims concerning the product's packaging, label and trade dress. In several proceedings before the Delhi High Court, the Court considered whether competing products reproduced important elements of the plaintiff's commercial presentation, including the wording, visual appearance, packaging, label and bottle design.
Importantly, the various Lahori Zeera proceedings were decided at different procedural stages. Several 2024 orders concerned interim or ex parte interim relief and prima facie findings, whereas the 2025 proceedings in Archian Foods Private Limited v. M/s Balaji Foods and Beverages & Anr. resulted in a final decree of permanent injunction. A further 2026 proceeding involving Deep Waters was disposed of pursuant to a settlement agreement.
Background and Development of the Lahori Brand
The Delhi High Court records state that the predecessor of Archian Foods Private Limited, M/s Archian Foods, adopted the trademark “LAHORI” in 2013 in relation to kulfi. In 2015, the business diversified into non-alcoholic beverages and launched “LAHORI ZEERA”. The business subsequently introduced other products under the LAHORI formative family, including LAHORI NIMBOO, LAHORI KACHA AAM, LAHORI SHIKANJI and other beverages.
The rights in the relevant trademarks and trade dress were stated by the plaintiff to have been transferred from M/s Archian Foods to Archian Foods Private Limited pursuant to a Deed of Assignment dated 30 November 2021. The Delhi High Court records also state that the predecessor had transferred its intellectual property to the plaintiff under that deed.
The plaintiff relied upon substantial sales, marketing and promotion to establish goodwill and reputation. In the 2025 proceedings, the Court recorded the plaintiff's submission that sales under the LAHORI ZEERA trademark/trade dress in financial year 2022–23 amounted to approximately Rs.203 crore, while the pleadings referred to overall sales of approximately Rs.432 crore for the LAHORI-formative products. These figures should properly be understood as figures placed before the Court by the plaintiff rather than as independently audited figures judicially determined after a full trial.
Intellectual Property Rights Involved
The Lahori Zeera proceedings illustrate the possibility of overlapping intellectual-property protection for different aspects of the same commercial product.
Trademark Protection
The Trade Marks Act, 1999 provides statutory protection to registered trademarks and also preserves the common-law remedy of passing off under Section 27(2). Archian Foods relied upon a portfolio of registered LAHORI-formative trademarks, including registrations in Classes 30 and 32. The Delhi High Court recorded the existence of several such registrations and also noted that additional applications for stylised LAHORI marks had been filed and were pending.
An important distinction, however, must be maintained between the registered LAHORI-formative marks and the specific “LAHORI ZEERA” word mark and related devices involved in some of the disputes. In the 2 May 2024 Devsar Industries proceedings, the Delhi High Court expressly observed that the word mark “LAHORI JEERA” and certain device marks were not registered in the plaintiff's favour. Nevertheless, the Court found that the plaintiff had prima facie demonstrated that long and continuous use, extensive promotion and marketing had resulted in substantial goodwill and reputation. Accordingly, trademark registration should not be treated as the only possible basis of protection. An unregistered mark may, where the legal requirements are satisfied, be protected through the action of passing off.
Copyright Protection in the Label
Copyright constituted another important layer of protection. The plaintiff obtained copyright registration bearing Registration No. A-146655/2023 for the “LAHORI ZEERA” label, classified as an artistic work. The Delhi High Court records expressly refer to this registration. The registration provided an additional basis upon which the plaintiff could seek protection for the artistic expression embodied in the label. In the 2024 proceedings, the Delhi High Court found, at the interim stage, a prima facie case of copyright infringement where the defendants' products reproduced substantial visual elements of the plaintiff's packaging and label.
This demonstrates an important principle of intellectual-property strategy: a competitor's alteration of a word or brand name may not necessarily eliminate liability if the competitor has also reproduced protectable artistic expression contained in the packaging or label. However, copyright protection and trademark protection operate differently. Copyright protects qualifying original expression, whereas trademark law primarily protects signs that distinguish the commercial source of goods or services.
Registered Design of the Bottle
The physical appearance of the Lahori Zeera bottle constituted another distinct intellectual-property asset. The Delhi High Court records that the plaintiff obtained registration for the shape and configuration of the Lahori Zeera bottle under Design No. 352339-001 under the Designs Act, 2000. Design protection is concerned with the visual features of an article for which the design has been validly registered, subject to the requirements and limitations of the Designs Act, 2000.
The Lahori Zeera proceedings therefore illustrate how different aspects of one commercial product may be protected through different legal mechanisms: trademarks for registered source-identifying signs, copyright for qualifying artistic expression and design registration for the registered appearance of the bottle.
A Significant Delhi High Court Proceeding: Archian Foods v. Shri Balaji Beverages
One of the important Lahori Zeera proceedings was Archian Foods Private Limited v. Shri Balaji Beverages & Ors., CS(COMM) 268/2024, before Justice Sanjeev Narula of the Delhi High Court. The order was passed on 2 April 2024. The plaintiff sought urgent interim relief against allegedly counterfeit products and also sought appointment of a Local Commissioner. The Court recorded competing products bearing marks including “TROUT LAHORI JEERA,” “DNM LAHORE JEERA” and “FROSTRY LOHORI JEERA.” The Court observed that the impugned products reproduced important elements of the plaintiff's presentation, including the colour scheme, manner and style of writing the marks, sliced-lemon device, label design and bottle shape.
The Court's comparison was therefore not limited to the spelling of the competing marks. It considered the overall visual presentation of the products. The Court also granted urgent interim relief and appointed a Local Commissioner. Because this was an interim proceeding, the findings should be understood in that procedural context rather than as a final adjudication after trial. The case demonstrates the importance of examining the overall commercial impression created by competing consumer products rather than relying exclusively upon isolated differences between individual words.
Archian Foods v. Devsar Industries: Similarity of Marks, Packaging and Bottle Design
A further significant proceeding was Archian Foods Private Limited v. Devsar Industries & Ors., CS(COMM) 354/2024, decided by Justice Sanjeev Narula on 2 May 2024. The plaintiff alleged that the defendants were manufacturing and selling lookalike products. The Court compared the competing products and found that the defendants had reproduced several features of the plaintiff's product, including the colour scheme, manner and style of writing “LAHORE JEERA,” the sliced-lemon device, label design and bottle shape.
The Court specifically observed that the competing products were nearly identical and that “LAHORE JEERA” was phonetically and structurally similar to “LAHORI ZEERA.” The Court further noted that the additional word “XAICA” appeared in a significantly smaller font and therefore did not necessarily remove the likelihood of confusion. The Court stated that the plaintiff had prima facie established goodwill and reputation through long and continuous use, extensive promotion and marketing. It also found a prima facie case of passing off and infringement and piracy of the plaintiff's registered copyright and bottle design. An ex parte interim order was consequently granted, together with directions concerning the Local Commissioners.
The decision is useful in understanding the protection of trade dress and overall product presentation. Although the Trade Marks Act, 1999 does not create a separate statutory cause of action expressly titled “trade dress infringement,” Indian courts may protect distinctive packaging, get-up and overall commercial presentation through trademark and passing-off principles, alongside copyright and design protection where the relevant statutory requirements are satisfied.
Archian Foods v. Erva Foods: “Slavish Copying”
Another important proceeding was Archian Foods Private Limited v. Erva Foods and Beverages Pvt.
Ltd. & Ors., CS(COMM) 813/2024, decided on 26 September 2024 by Justice Amit Bansal.
The plaintiff alleged infringement of its trademark, copyright and design and sought permanent injunction and other reliefs. The Court compared the plaintiff's trade dress, packaging, label and bottle with the defendants' products. The Court stated that the defendants had “slavishly copied” the plaintiff's labels, packaging, trademark and trade dress and concluded that a prima facie case of infringement of trademark, copyright and design, as well as passing off, had been made out.
The Court also held that the balance of convenience favoured the plaintiff and that irreparable injury would result if an ex parte interim injunction were not granted. Again, this distinction is important: the September 2024 order was an interim order, and the Court's conclusion was expressly framed in terms of a prima facie case.
Archian Foods v. Balaji Foods and Beverages: Permanent Injunction in 2025
A particularly important development occurred in Archian Foods Private Limited v. M/s Balaji Foods and Beverages & Anr., CS(COMM) 503/2024. The suit concerned the defendants' alleged use of the mark/trade dress “LAHOR ZEERA”, which the plaintiff alleged was deceptively similar to its LAHORI ZEERA mark and trade dress. The plaintiff sought permanent injunction in relation to trademark infringement, copyright infringement, passing off, piracy of registered design and related reliefs. An ex parte ad-interim injunction was granted on 31 May 2024. A Local Commissioner subsequently visited the defendants' premises, and the proceedings continued after service of summons. The defendants did not enter appearance or file written statements, and they were ultimately proceeded ex parte. The interim injunction was confirmed pending final adjudication.
On 8 August 2025, Justice Manmeet Pritam Singh Arora considered whether the matter could be decreed under Order VIII Rule 10 of the Code of Civil Procedure, 1908. The Court concluded that the suit did not require a trial in the circumstances and that the plaintiff was entitled to a permanent injunction. The Court held that the defendants' conduct involved unfair competition through packaging, labels and bottle design that infringed the plaintiff's copyright, trademarks and design registrations. It therefore granted a permanent injunction in favour of Archian Foods. The interim order dated 31 May 2024 merged into the final decree. The Court also awarded nominal damages of Rs.50,000 against the defendants and awarded costs. The 2025 decision is therefore materially different from the 2024 proceedings: it resulted in a final decree of permanent injunction, rather than merely an interim prima facie finding.
A Note on the Designs Act Reference
The 8 August 2025 order reproduces, in paragraph 1, the plaintiff's pleading referring to the “Designs Act, 2002.” However, the same judgment expressly records the plaintiff's bottle as being registered under the Designs Act, 2000, with Design No. 352339-001. The governing Indian statute is the Designs Act, 2000. Accordingly, the correct statutory reference in an academic article is Designs Act, 2000, not Designs Act, 2002.
Archian Foods v. Deep Waters: Settlement in 2026
The Lahori Zeera enforcement proceedings continued into 2026. In Archian Foods Private Limited v. Deep Waters & Ors., CS(COMM) 238/2025, the plaintiff sought permanent injunction against the defendants' use of LAHORI ZEERA and other allegedly deceptively similar marks in relation to non-alcoholic beverages. The Delhi High Court had previously granted an ex parte ad-interim injunction on 19 March 2025, which remained in force during the proceedings. The parties were subsequently referred to mediation and entered into a Settlement Agreement dated 19 February 2026.
The settlement included an undertaking concerning destruction of goods seized by the Local Commissioner. On 25 April 2026, Justice Jyoti Singh found the settlement lawful and decreed the suit in terms of the Settlement Agreement. This proceeding should not be described as a final judicial finding, after trial, that the defendants infringed the plaintiff's rights. Rather, it is an example of court-recorded settlement and continued enforcement of the plaintiff's asserted IP rights.
Application of Established Trademark Principles
The Lahori Zeera decisions can be understood in the context of established principles of Indian trademark law. In Cadila Health Care Ltd. v. Cadila Pharmaceuticals Ltd., (2001) 5 SCC 73, the Supreme Court considered the principles governing deceptive similarity and likelihood of confusion. The Court recognised the relevance of factors such as the nature of the marks, degree of resemblance, nature of the goods, class of purchasers and the circumstances in which the goods are purchased.
The principle is relevant to the Lahori Zeera litigation because the Delhi High Court considered not merely spelling differences but also phonetic similarity, visual presentation, packaging and the overall appearance of the competing products. In Devsar Industries, for example, the Court specifically considered the similarity between “LAHORE JEERA” and “LAHORI ZEERA.”
Another relevant authority is Midas Hygiene Industries (P) Ltd. v. Sudhir Bhatia, (2004) 3 SCC 90. The Supreme Court dealt with the grant of injunctions in cases involving infringement of trademark or copyright and emphasised the significance of protecting intellectual-property rights where infringement is established. The decision is commonly relied upon for the proposition that delay alone does not necessarily defeat injunctive relief in an infringement action. These authorities provide the broader legal framework within which the Delhi High Court's interim protection in the Lahori Zeera proceedings can be understood.
Importance of the Lahori Zeera Litigation for Indian IP Law
First, the value of a layered IP strategy
The dispute illustrates the importance of protecting different aspects of a commercial product through appropriate forms of IP protection. Trademark registrations can protect source-identifying marks; copyright can protect qualifying artistic expression; and design registration can protect the registered visual features of an article.
Second, registration is not the entire story
The proceedings demonstrate the importance of prior use, goodwill and reputation. In Devsar Industries, the Court noted that although the word mark “LAHORI JEERA” and certain device marks were not registered in the plaintiff's favour, the plaintiff had prima facie demonstrated substantial goodwill and reputation through continuous use and promotion. This is particularly relevant to passing off, where registration is not an essential prerequisite.
Third, packaging and overall presentation matter
The courts repeatedly examined the overall commercial appearance of the products. Colour combinations, label arrangements, visual devices, bottle shape and the presentation of words were all considered in determining whether the competing products created a likelihood of confusion or amounted to passing off.
Fourth, interim relief can be commercially significant
The 2024 proceedings demonstrate the practical importance of urgent interim relief in counterfeit and lookalike-product disputes. The Delhi High Court granted ex parte interim protection and appointed Local Commissioners in circumstances where the plaintiff alleged ongoing manufacture and sale of infringing products.
Fifth, procedural conduct can influence the final outcome
The 2025 Balaji Foods and Beverages matter illustrates the importance of participating in litigation. After the defendants failed to appear and were proceeded ex parte, the Court considered the record and granted a final decree of permanent injunction under Order VIII Rule 10 CPC.
Conclusion
The Lahori Zeera litigation provides a useful contemporary case study of the interaction between different forms of intellectual-property protection in India. The disputes demonstrate that the commercial identity of an FMCG product may consist of several legally significant elements. A trademark may identify the source of the goods; a label may contain protectable artistic expression; and the physical appearance of a bottle may be protected through registered design rights. Packaging, get-up and trade dress may also become relevant to trademark and passing-off disputes where the legal requirements are satisfied.
The Delhi High Court's Lahori Zeera proceedings further demonstrate that courts may consider the overall commercial impression created by competing products. Phonetic similarity, visual resemblance, packaging, colour combinations, label arrangement, bottle shape and the likely perception of consumers can all become relevant to the assessment of trademark infringement and passing off.
At the same time, the procedural posture of each decision must be carefully recognised. The 2024 cases primarily involved interim protection and prima facie findings, while the 2025 Balaji Foods and Beverages case resulted in a final decree of permanent injunction. The 2026 Deep Waters matter was ultimately resolved through a settlement agreement recorded and decreed by the Court. Taken together, these proceedings demonstrate the practical value of a layered intellectual-property strategy combining registration, continuous use, documentation of goodwill, copyright protection, design registration and prompt enforcement. For Indian businesses operating in the FMCG and beverage sectors, the Lahori Zeera litigation therefore provides a useful illustration of how intellectual-property rights can be deployed collectively to protect a brand's commercial identity.
Key Case References

Archian Foods Private Limited v. Shri Balaji Beverages & Ors., CS(COMM) 268/2024, Delhi HighCourt, order dated 2 April 2024.

Archian Foods Private Limited v. Devsar Industries & Ors., CS(COMM) 354/2024, Delhi High Court,order dated 2 May 2024.

Archian Foods Private Limited v. Erva Foods and Beverages Pvt. Ltd. & Ors., CS(COMM) 813/2024,Delhi High Court, order dated 26 September 2024.

Archian Foods Private Limited v. M/s Balaji Foods and Beverages & Anr., CS(COMM) 503/2024,Delhi High Court, final order dated 8 August 2025.

Archian Foods Private Limited v. Deep Waters & Ors., CS(COMM) 238/2025, Delhi High Court, orderdated 25 April 2026.

Cadila Health Care Ltd. v. Cadila Pharmaceuticals Ltd., (2001) 5 SCC 73.

Midas Hygiene Industries (P) Ltd. v. Sudhir Bhatia, (2004) 3 SCC 90.

Intellectual property rights play an important role in protecting the goodwill, reputation, brand identity and distinctive commercial features of consumer products. The litigation surrounding “LAHORI ZEERA”, a non-alcoholic beverage brand marketed by Archian Foods Private Limited, provides a useful contemporary example of the interaction between trademark law, passing off, copyright and registered design protection in India.

The Lahori Zeera disputes are particularly significant because the proprietor's claims were not confined to the use of a brand name. The proceedings involved allegations of trademark infringement, passing off, copyright infringement and piracy of a registered bottle design, together with claims concerning the product's packaging, label and trade dress. In several proceedings before the Delhi High Court, the Court considered whether competing products reproduced important elements of the plaintiff's commercial presentation, including the wording, visual appearance, packaging, label and bottle design.

Importantly, the various Lahori Zeera proceedings were decided at different procedural stages. Several 2024 orders concerned interim or ex parte interim relief and prima facie findings, whereas the 2025 proceedings in Archian Foods Private Limited v. M/s Balaji Foods and Beverages & Anr. resulted in a final decree of permanent injunction. A further 2026 proceeding involving Deep Waters was disposed of pursuant to a settlement agreement.

Background and Development of the Lahori Brand

The Delhi High Court records state that the predecessor of Archian Foods Private Limited, M/s Archian Foods, adopted the trademark “LAHORI” in 2013 in relation to kulfi. In 2015, the business diversified into non-alcoholic beverages and launched “LAHORI ZEERA”. The business subsequently introduced other products under the LAHORI formative family, including LAHORI NIMBOO, LAHORI KACHA AAM, LAHORI SHIKANJI and other beverages.

The rights in the relevant trademarks and trade dress were stated by the plaintiff to have been transferred from M/s Archian Foods to Archian Foods Private Limited pursuant to a Deed of Assignment dated 30 November 2021. The Delhi High Court records also state that the predecessor had transferred its intellectual property to the plaintiff under that deed.

The plaintiff relied upon substantial sales, marketing and promotion to establish goodwill and reputation. In the 2025 proceedings, the Court recorded the plaintiff's submission that sales under the LAHORI ZEERA trademark/trade dress in financial year 2022–23 amounted to approximately Rs.203 crore, while the pleadings referred to overall sales of approximately Rs.432 crore for the LAHORI-formative products. These figures should properly be understood as figures placed before the Court by the plaintiff rather than as independently audited figures judicially determined after a full trial.

Intellectual Property Rights Involved

The Lahori Zeera proceedings illustrate the possibility of overlapping intellectual-property protection for different aspects of the same commercial product.

Trademark Protection

The Trade Marks Act, 1999 provides statutory protection to registered trademarks and also preserves the common-law remedy of passing off under Section 27(2). Archian Foods relied upon a portfolio of registered LAHORI-formative trademarks, including registrations in Classes 30 and 32. The Delhi High Court recorded the existence of several such registrations and also noted that additional applications for stylised LAHORI marks had been filed and were pending.

An important distinction, however, must be maintained between the registered LAHORI-formative marks and the specific “LAHORI ZEERA” word mark and related devices involved in some of the disputes. In the 2 May 2024 Devsar Industries proceedings, the Delhi High Court expressly observed that the word mark “LAHORI JEERA” and certain device marks were not registered in the plaintiff's favour. Nevertheless, the Court found that the plaintiff had prima facie demonstrated that long and continuous use, extensive promotion and marketing had resulted in substantial goodwill and reputation. Accordingly, trademark registration should not be treated as the only possible basis of protection. An unregistered mark may, where the legal requirements are satisfied, be protected through the action of passing off.

Copyright Protection in the Label

Copyright constituted another important layer of protection. The plaintiff obtained copyright registration bearing Registration No. A-146655/2023 for the “LAHORI ZEERA” label, classified as an artistic work. The Delhi High Court records expressly refer to this registration. The registration provided an additional basis upon which the plaintiff could seek protection for the artistic expression embodied in the label. In the 2024 proceedings, the Delhi High Court found, at the interim stage, a prima facie case of copyright infringement where the defendants' products reproduced substantial visual elements of the plaintiff's packaging and label.

This demonstrates an important principle of intellectual-property strategy: a competitor's alteration of a word or brand name may not necessarily eliminate liability if the competitor has also reproduced protectable artistic expression contained in the packaging or label. However, copyright protection and trademark protection operate differently. Copyright protects qualifying original expression, whereas trademark law primarily protects signs that distinguish the commercial source of goods or services.

Registered Design of the Bottle

The physical appearance of the Lahori Zeera bottle constituted another distinct intellectual-property asset. The Delhi High Court records that the plaintiff obtained registration for the shape and configuration of the Lahori Zeera bottle under Design No. 352339-001 under the Designs Act, 2000. Design protection is concerned with the visual features of an article for which the design has been validly registered, subject to the requirements and limitations of the Designs Act, 2000.

The Lahori Zeera proceedings therefore illustrate how different aspects of one commercial product may be protected through different legal mechanisms: trademarks for registered source-identifying signs, copyright for qualifying artistic expression and design registration for the registered appearance of the bottle.

A Significant Delhi High Court Proceeding: Archian Foods v. Shri Balaji Beverages

One of the important Lahori Zeera proceedings was Archian Foods Private Limited v. Shri Balaji Beverages & Ors., CS(COMM) 268/2024, before Justice Sanjeev Narula of the Delhi High Court. The order was passed on 2 April 2024. The plaintiff sought urgent interim relief against allegedly counterfeit products and also sought appointment of a Local Commissioner. The Court recorded competing products bearing marks including “TROUT LAHORI JEERA,” “DNM LAHORE JEERA” and “FROSTRY LOHORI JEERA.” The Court observed that the impugned products reproduced important elements of the plaintiff's presentation, including the colour scheme, manner and style of writing the marks, sliced-lemon device, label design and bottle shape.

The Court's comparison was therefore not limited to the spelling of the competing marks. It considered the overall visual presentation of the products. The Court also granted urgent interim relief and appointed a Local Commissioner. Because this was an interim proceeding, the findings should be understood in that procedural context rather than as a final adjudication after trial. The case demonstrates the importance of examining the overall commercial impression created by competing consumer products rather than relying exclusively upon isolated differences between individual words.

Archian Foods v. Devsar Industries: Similarity of Marks, Packaging and Bottle Design

A further significant proceeding was Archian Foods Private Limited v. Devsar Industries & Ors., CS(COMM) 354/2024, decided by Justice Sanjeev Narula on 2 May 2024. The plaintiff alleged that the defendants were manufacturing and selling lookalike products. The Court compared the competing products and found that the defendants had reproduced several features of the plaintiff's product, including the colour scheme, manner and style of writing “LAHORE JEERA,” the sliced-lemon device, label design and bottle shape.

The Court specifically observed that the competing products were nearly identical and that “LAHORE JEERA” was phonetically and structurally similar to “LAHORI ZEERA.” The Court further noted that the additional word “XAICA” appeared in a significantly smaller font and therefore did not necessarily remove the likelihood of confusion. The Court stated that the plaintiff had prima facie established goodwill and reputation through long and continuous use, extensive promotion and marketing. It also found a prima facie case of passing off and infringement and piracy of the plaintiff's registered copyright and bottle design. An ex parte interim order was consequently granted, together with directions concerning the Local Commissioners.

The decision is useful in understanding the protection of trade dress and overall product presentation. Although the Trade Marks Act, 1999 does not create a separate statutory cause of action expressly titled “trade dress infringement,” Indian courts may protect distinctive packaging, get-up and overall commercial presentation through trademark and passing-off principles, alongside copyright and design protection where the relevant statutory requirements are satisfied.

Archian Foods v. Erva Foods: “Slavish Copying”

Another important proceeding was Archian Foods Private Limited v. Erva Foods and Beverages Pvt.

Ltd. & Ors., CS(COMM) 813/2024, decided on 26 September 2024 by Justice Amit Bansal.

The plaintiff alleged infringement of its trademark, copyright and design and sought permanent injunction and other reliefs. The Court compared the plaintiff's trade dress, packaging, label and bottle with the defendants' products. The Court stated that the defendants had “slavishly copied” the plaintiff's labels, packaging, trademark and trade dress and concluded that a prima facie case of infringement of trademark, copyright and design, as well as passing off, had been made out.

The Court also held that the balance of convenience favoured the plaintiff and that irreparable injury would result if an ex parte interim injunction were not granted. Again, this distinction is important: the September 2024 order was an interim order, and the Court's conclusion was expressly framed in terms of a prima facie case.

Archian Foods v. Balaji Foods and Beverages: Permanent Injunction in 2025

A particularly important development occurred in Archian Foods Private Limited v. M/s Balaji Foods and Beverages & Anr., CS(COMM) 503/2024. The suit concerned the defendants' alleged use of the mark/trade dress “LAHOR ZEERA”, which the plaintiff alleged was deceptively similar to its LAHORI ZEERA mark and trade dress. The plaintiff sought permanent injunction in relation to trademark infringement, copyright infringement, passing off, piracy of registered design and related reliefs. An ex parte ad-interim injunction was granted on 31 May 2024. A Local Commissioner subsequently visited the defendants' premises, and the proceedings continued after service of summons. The defendants did not enter appearance or file written statements, and they were ultimately proceeded ex parte. The interim injunction was confirmed pending final adjudication.

On 8 August 2025, Justice Manmeet Pritam Singh Arora considered whether the matter could be decreed under Order VIII Rule 10 of the Code of Civil Procedure, 1908. The Court concluded that the suit did not require a trial in the circumstances and that the plaintiff was entitled to a permanent injunction. The Court held that the defendants' conduct involved unfair competition through packaging, labels and bottle design that infringed the plaintiff's copyright, trademarks and design registrations. It therefore granted a permanent injunction in favour of Archian Foods. The interim order dated 31 May 2024 merged into the final decree. The Court also awarded nominal damages of Rs.50,000 against the defendants and awarded costs. The 2025 decision is therefore materially different from the 2024 proceedings: it resulted in a final decree of permanent injunction, rather than merely an interim prima facie finding.

A Note on the Designs Act Reference

The 8 August 2025 order reproduces, in paragraph 1, the plaintiff's pleading referring to the “Designs Act, 2002.” However, the same judgment expressly records the plaintiff's bottle as being registered under the Designs Act, 2000, with Design No. 352339-001. The governing Indian statute is the Designs Act, 2000. Accordingly, the correct statutory reference in an academic article is Designs Act, 2000, not Designs Act, 2002.

Archian Foods v. Deep Waters: Settlement in 2026

The Lahori Zeera enforcement proceedings continued into 2026. In Archian Foods Private Limited v. Deep Waters & Ors., CS(COMM) 238/2025, the plaintiff sought permanent injunction against the defendants' use of LAHORI ZEERA and other allegedly deceptively similar marks in relation to non-alcoholic beverages. The Delhi High Court had previously granted an ex parte ad-interim injunction on 19 March 2025, which remained in force during the proceedings. The parties were subsequently referred to mediation and entered into a Settlement Agreement dated 19 February 2026.

The settlement included an undertaking concerning destruction of goods seized by the Local Commissioner. On 25 April 2026, Justice Jyoti Singh found the settlement lawful and decreed the suit in terms of the Settlement Agreement. This proceeding should not be described as a final judicial finding, after trial, that the defendants infringed the plaintiff's rights. Rather, it is an example of court-recorded settlement and continued enforcement of the plaintiff's asserted IP rights.

Application of Established Trademark Principles

The Lahori Zeera decisions can be understood in the context of established principles of Indian trademark law. In Cadila Health Care Ltd. v. Cadila Pharmaceuticals Ltd., (2001) 5 SCC 73, the Supreme Court considered the principles governing deceptive similarity and likelihood of confusion. The Court recognised the relevance of factors such as the nature of the marks, degree of resemblance, nature of the goods, class of purchasers and the circumstances in which the goods are purchased.

The principle is relevant to the Lahori Zeera litigation because the Delhi High Court considered not merely spelling differences but also phonetic similarity, visual presentation, packaging and the overall appearance of the competing products. In Devsar Industries, for example, the Court specifically considered the similarity between “LAHORE JEERA” and “LAHORI ZEERA.”

Another relevant authority is Midas Hygiene Industries (P) Ltd. v. Sudhir Bhatia, (2004) 3 SCC 90. The Supreme Court dealt with the grant of injunctions in cases involving infringement of trademark or copyright and emphasised the significance of protecting intellectual-property rights where infringement is established. The decision is commonly relied upon for the proposition that delay alone does not necessarily defeat injunctive relief in an infringement action. These authorities provide the broader legal framework within which the Delhi High Court's interim protection in the Lahori Zeera proceedings can be understood.

Importance of the Lahori Zeera Litigation for Indian IP Law

First, the value of a layered IP strategy

The dispute illustrates the importance of protecting different aspects of a commercial product through appropriate forms of IP protection. Trademark registrations can protect source-identifying marks; copyright can protect qualifying artistic expression; and design registration can protect the registered visual features of an article.

Second, registration is not the entire story

The proceedings demonstrate the importance of prior use, goodwill and reputation. In Devsar Industries, the Court noted that although the word mark “LAHORI JEERA” and certain device marks were not registered in the plaintiff's favour, the plaintiff had prima facie demonstrated substantial goodwill and reputation through continuous use and promotion. This is particularly relevant to passing off, where registration is not an essential prerequisite.

Third, packaging and overall presentation matter

The courts repeatedly examined the overall commercial appearance of the products. Colour combinations, label arrangements, visual devices, bottle shape and the presentation of words were all considered in determining whether the competing products created a likelihood of confusion or amounted to passing off.

Fourth, interim relief can be commercially significant

The 2024 proceedings demonstrate the practical importance of urgent interim relief in counterfeit and lookalike-product disputes. The Delhi High Court granted ex parte interim protection and appointed Local Commissioners in circumstances where the plaintiff alleged ongoing manufacture and sale of infringing products.

Fifth, procedural conduct can influence the final outcome

The 2025 Balaji Foods and Beverages matter illustrates the importance of participating in litigation. After the defendants failed to appear and were proceeded ex parte, the Court considered the record and granted a final decree of permanent injunction under Order VIII Rule 10 CPC.

Conclusion

The Lahori Zeera litigation provides a useful contemporary case study of the interaction between different forms of intellectual-property protection in India. The disputes demonstrate that the commercial identity of an FMCG product may consist of several legally significant elements. A trademark may identify the source of the goods; a label may contain protectable artistic expression; and the physical appearance of a bottle may be protected through registered design rights. Packaging, get-up and trade dress may also become relevant to trademark and passing-off disputes where the legal requirements are satisfied.

The Delhi High Court's Lahori Zeera proceedings further demonstrate that courts may consider the overall commercial impression created by competing products. Phonetic similarity, visual resemblance, packaging, colour combinations, label arrangement, bottle shape and the likely perception of consumers can all become relevant to the assessment of trademark infringement and passing off.

At the same time, the procedural posture of each decision must be carefully recognised. The 2024 cases primarily involved interim protection and prima facie findings, while the 2025 Balaji Foods and Beverages case resulted in a final decree of permanent injunction. The 2026 Deep Waters matter was ultimately resolved through a settlement agreement recorded and decreed by the Court. Taken together, these proceedings demonstrate the practical value of a layered intellectual-property strategy combining registration, continuous use, documentation of goodwill, copyright protection, design registration and prompt enforcement. For Indian businesses operating in the FMCG and beverage sectors, the Lahori Zeera litigation therefore provides a useful illustration of how intellectual-property rights can be deployed collectively to protect a brand's commercial identity.

Key Case References

Archian Foods Private Limited v. Shri Balaji Beverages & Ors., CS(COMM) 268/2024, Delhi HighCourt, order dated 2 April 2024.
Archian Foods Private Limited v. Devsar Industries & Ors., CS(COMM) 354/2024, Delhi High Court,order dated 2 May 2024.
Archian Foods Private Limited v. Erva Foods and Beverages Pvt. Ltd. & Ors., CS(COMM) 813/2024,Delhi High Court, order dated 26 September 2024.
Archian Foods Private Limited v. M/s Balaji Foods and Beverages & Anr., CS(COMM) 503/2024,Delhi High Court, final order dated 8 August 2025.
Archian Foods Private Limited v. Deep Waters & Ors., CS(COMM) 238/2025, Delhi High Court, orderdated 25 April 2026.
Cadila Health Care Ltd. v. Cadila Pharmaceuticals Ltd., (2001) 5 SCC 73.
Midas Hygiene Industries (P) Ltd. v. Sudhir Bhatia, (2004) 3 SCC 90.