KRBL Limited v. Praveen Kumar Buyyani & Ors- Trademark Infringement Case

KRBL Limited v. Praveen Kumar Buyyani & Ors- Trademark Infringement Case. In a judgment dated 15 January 2025, the Delhi High Court delivered a strong message in support of brand integrity and consumer protection. The case of KRBL Limited v. Praveen Kumar Buyyani & Ors. centered on the alleged trademark infringement of KRBL’s popular “India Gate” brand — a name synonymous with high-quality basmati rice in India and abroad. The respondent’s use of the brand name “Bharat Gate”, accompanied by a visually and conceptually similar logo and packaging, prompted KRBL to seek judicial relief. The Court's ruling in KRBL’s favor not only protected an established brand but also clarified critical aspects of trademark law.
Background of the Dispute
KRBL Limited, the world’s leading basmati rice exporter, has been the registered proprietor of the “India Gate” trademark since 1993. With decades of branding, advertising, and consistent product quality, “India Gate” has earned substantial goodwill among consumers. In 2020, KRBL became aware that Praveen Kumar Buyyani and associates were marketing rice under the label “Bharat Gate”. KRBL alleged that this competing brand was not only phonetically similar but also used a near-identical design — including the India Gate monument on the product packaging. This, they argued, was intended to mislead consumers, riding on the goodwill of KRBL's established mark. The Commercial Court initially granted an ex parte ad interim injunction in KRBL’s favor in 2020. However, in 2024, the injunction was vacated, prompting KRBL to appeal the decision before the Delhi High Court.
Legal Issues Raised
The case revolved around key trademark law principles, including:

Likelihood of confusion among consumers

Infringement of visual and phonetic elements

Acquired distinctiveness of a descriptive mark

Doctrine of deceptive similarity

Bad faith adoption

KRBL’s appeal emphasized the intentional mimicry of its brand identity and the public interest in preventing consumer deception.
Analysis by the Delhi High Court
The bench, comprising Justice C. Hari Shankar and Justice Ajay Digpaul, reinstated the interim injunction in favor of KRBL. The Court conducted a detailed analysis of the visual, phonetic, and conceptual components of both marks, concluding that “Bharat Gate” amounted to a deliberate attempt to misappropriate KRBL’s brand equity.
1. Phonetic and Conceptual Similarity
The Court noted that the words “Bharat” and “India” are identical, both referring to the same country. Coupled with the common use of the word “Gate”, the two marks were found to be confusingly similar in the minds of average consumers, particularly in rural and semi-urban markets where products are often purchased based on visual cues and brand familiarity.
2. Visual Similarity and Packaging
One of the most striking findings was the visual imitation of the product packaging. Both brands prominently displayed the India Gate monument — a unique architectural symbol strongly associated with KRBL’s product. The layout, color scheme, and presentation style further reinforced the Court’s view that the infringing mark aimed to pass off as “India Gate.”
3. Intention to Deceive (Idea Infringement)
The Court emphasized that intent to deceive, while not a necessary requirement to prove trademark infringement, was evident in this case. The choice of name and imagery reflected a conscious decision to mislead consumers and capitalize on the brand reputation painstakingly built by KRBL over decades.
4. Rejection of the “Generic” Defense
The respondents argued that “India Gate” was a combination of generic terms and thus not entitled to exclusive protection. However, the Court reiterated that distinctiveness is judged based on the market perception and usage over time. It held that “India Gate” had acquired a secondary meaning due to its widespread recognition, making it a protectable trademark under Indian law.
Legal Provisions Cited

Section 29(2) of the Trade Marks Act, 1999: Infringement occurs when a mark is similar to a registered mark and is used for identical or similar goods or services, causing a likelihood of confusion.

Section 11: Grounds for refusal of registration where the use of a mark would create confusion or association with an earlier mark.

Doctrine of “First in the Market”: The Court also upheld that first use and continuous commercial exploitation grant strong enforceable rights under Indian trademark jurisprudence.

Conclusion
The Delhi High Court's ruling in favor of KRBL Limited is a powerful reaffirmation of India’s commitment to intellectual property rights protection. The case not only protects a legacy brand like “India Gate” but also deters businesses from engaging in brand mimicry. This decision serves as a valuable legal benchmark, particularly for fast-moving consumer goods (FMCG) companies where branding is often the biggest differentiator. Going forward, entities will need to exercise greater caution and originality in brand creation, lest they face serious legal consequences for infringement. As India becomes increasingly brand-conscious and globalized, the protection of trademarks will remain a cornerstone of commercial trust and consumer loyalty. The message is clear: trademark registration must be respected, and goodwill must not be misappropriated.

In a judgment dated 15 January 2025, the Delhi High Court delivered a strong message in support of brand integrity and consumer protection. The case of KRBL Limited v. Praveen Kumar Buyyani & Ors. centered on the alleged trademark infringement of KRBL’s popular “India Gate” brand — a name synonymous with high-quality basmati rice in India and abroad. The respondent’s use of the brand name “Bharat Gate”, accompanied by a visually and conceptually similar logo and packaging, prompted KRBL to seek judicial relief. The Court's ruling in KRBL’s favor not only protected an established brand but also clarified critical aspects of trademark law.

Background of the Dispute

KRBL Limited, the world’s leading basmati rice exporter, has been the registered proprietor of the “India Gate” trademark since 1993. With decades of branding, advertising, and consistent product quality, “India Gate” has earned substantial goodwill among consumers. In 2020, KRBL became aware that Praveen Kumar Buyyani and associates were marketing rice under the label “Bharat Gate”. KRBL alleged that this competing brand was not only phonetically similar but also used a near-identical design — including the India Gate monument on the product packaging. This, they argued, was intended to mislead consumers, riding on the goodwill of KRBL's established mark. The Commercial Court initially granted an ex parte ad interim injunction in KRBL’s favor in 2020. However, in 2024, the injunction was vacated, prompting KRBL to appeal the decision before the Delhi High Court.

Legal Issues Raised

The case revolved around key trademark law principles, including:

Likelihood of confusion among consumers
Infringement of visual and phonetic elements
Acquired distinctiveness of a descriptive mark
Doctrine of deceptive similarity
Bad faith adoption

KRBL’s appeal emphasized the intentional mimicry of its brand identity and the public interest in preventing consumer deception.

Analysis by the Delhi High Court

The bench, comprising Justice C. Hari Shankar and Justice Ajay Digpaul, reinstated the interim injunction in favor of KRBL. The Court conducted a detailed analysis of the visual, phonetic, and conceptual components of both marks, concluding that “Bharat Gate” amounted to a deliberate attempt to misappropriate KRBL’s brand equity.

1. Phonetic and Conceptual Similarity

The Court noted that the words “Bharat” and “India” are identical, both referring to the same country. Coupled with the common use of the word “Gate”, the two marks were found to be confusingly similar in the minds of average consumers, particularly in rural and semi-urban markets where products are often purchased based on visual cues and brand familiarity.

2. Visual Similarity and Packaging

One of the most striking findings was the visual imitation of the product packaging. Both brands prominently displayed the India Gate monument — a unique architectural symbol strongly associated with KRBL’s product. The layout, color scheme, and presentation style further reinforced the Court’s view that the infringing mark aimed to pass off as “India Gate.”

3. Intention to Deceive (Idea Infringement)

The Court emphasized that intent to deceive, while not a necessary requirement to prove trademark infringement, was evident in this case. The choice of name and imagery reflected a conscious decision to mislead consumers and capitalize on the brand reputation painstakingly built by KRBL over decades.

4. Rejection of the “Generic” Defense

The respondents argued that “India Gate” was a combination of generic terms and thus not entitled to exclusive protection. However, the Court reiterated that distinctiveness is judged based on the market perception and usage over time. It held that “India Gate” had acquired a secondary meaning due to its widespread recognition, making it a protectable trademark under Indian law.

Legal Provisions Cited

Section 29(2) of the Trade Marks Act, 1999: Infringement occurs when a mark is similar to a registered mark and is used for identical or similar goods or services, causing a likelihood of confusion.
Section 11: Grounds for refusal of registration where the use of a mark would create confusion or association with an earlier mark.
Doctrine of “First in the Market”: The Court also upheld that first use and continuous commercial exploitation grant strong enforceable rights under Indian trademark jurisprudence.

Conclusion

The Delhi High Court's ruling in favor of KRBL Limited is a powerful reaffirmation of India’s commitment to intellectual property rights protection. The case not only protects a legacy brand like “India Gate” but also deters businesses from engaging in brand mimicry. This decision serves as a valuable legal benchmark, particularly for fast-moving consumer goods (FMCG) companies where branding is often the biggest differentiator. Going forward, entities will need to exercise greater caution and originality in brand creation, lest they face serious legal consequences for infringement. As India becomes increasingly brand-conscious and globalized, the protection of trademarks will remain a cornerstone of commercial trust and consumer loyalty. The message is clear: trademark registration must be respected, and goodwill must not be misappropriated.