Introduction

This case is a legal battle between two companies in Coimbatore, India, both using the word “Anugraha” in their business names. Anugraha Castings, a partnership firm, and Anugraha Valve Castings Limited, a company, clashed over who has the right to use “Anugraha” as a trademark. The dispute reached the Madras High Court when Anugraha Castings challenged the Commercial Court’s decision on which issues should be considered in a related lawsuit. This summary explains the facts, the dispute, the court’s reasoning, and the final decision in simple language, while keeping all legal provisions intact, to help law students and junior lawyers understand the case.

Background

Anugraha Valve Castings Limited (the respondent) claimed they started using the word “Anugraha” as a trademark in 2003. They registered it as a trademark (Registration No. 5117934) on 04.09.2021 for use in Classes 6 (metals and alloys), 7 (machines and machine tools), and 40 (material treatment), which are related to the alloys and casting industry.

The respondent sent a cease-and-desist notice to Anugraha Castings in 2021, asking them to stop using “Anugraha” in their business, claiming it violated their trademark rights. However, they did not file a lawsuit until 2025, when they filed a commercial suit (C.O.S.No.2 of 2025) in the Commercial Court, Coimbatore. The suit asked for court orders to stop Anugraha Castings from using “Anugraha” and to enforce the respondent’s trademark rights.

Anugraha Castings, as defendants in the suit, argued that the respondent’s trademark was invalid because “Anugraha” is a common word used in seven languages and not a unique term created by the respondent. They also claimed the respondent lied to the Trademark Registry by saying “Anugraha” was a coined (made-up) word.

Anugraha Castings filed a Civil Revision Petition under Article 227 of the Indian Constitution in the Madras High Court. They asked the court to order the Commercial Court to include nine specific issues (numbered 4 to 12 in their draft) in the lawsuit. On 09.06.2025, the Commercial Court framed some issues for the lawsuit after hearing both sides but did not include all the issues proposed by Anugraha Castings, especially those challenging the validity of the respondent’s trademark. This led Anugraha Castings to file the revision petition in the High Court.

The Dispute

The main issue was whether the Commercial Court made a mistake by not including all of Anugraha Castings’ proposed issues, particularly those questioning the validity of the respondent’s trademark. Anugraha Castings argued that “Anugraha” is a common word, not unique to the respondent, and that the respondent misled the Trademark Registry to get the registration. They wanted the Commercial Court to frame issues that would allow them to challenge the trademark’s validity and possibly seek its cancellation (rectification). The respondent, however, argued that their trademark was validly registered, that “Anugraha” was not a common term in their industry, and that Anugraha Castings’ challenge was weak and too late.

The case involves key provisions of the Trade Marks Act, 1999, which governs trademarks in India:

Detailed Reasoning

The court agreed that Section 124 allows a defendant to challenge a trademark’s validity, but only if they present a strong and believable case (prima facie tenable). The petitioners’ main argument was that “Anugraha” is a common word in seven languages. However, the court said this didn’t matter unless “Anugraha” was a common term in the alloys and casting industry (Classes 6, 7, and 40). The petitioners provided no evidence that it was common in this industry. The respondent’s explanation—that “Anugraha” was coined from the founder’s and his wife’s names and matched their company name—seemed reasonable and believable at this stage. The court concluded there was no strong case to question the trademark’s validity, so the Commercial Court was right not to frame an issue about invalidity.

Section 124 and Prima Facie Requirement

The court clarified that Section 124 doesn’t require framing an issue for every claim of invalidity. The claim must be strong enough to justify pausing the lawsuit and allowing a rectification challenge. The court referred to the Supreme Court’s ruling in Patel Field Marshal Agencies, which said that only credible claims of invalidity should lead to framing an issue, to avoid delays from weak or frivolous claims. Since the petitioners’ claim about “Anugraha” being a common word lacked evidence in the context of the industry, it didn’t meet the threshold for framing an issue.

Decision

The court refused to frame an issue on the invalidity of the respondent’s trademark, finding no strong or believable case to support it. The court upheld the Commercial Court’s decision not to include this issue, as the petitioners failed to show that “Anugraha” was a common term in the alloys and casting industry. There were no orders for costs, and the related Civil Miscellaneous Petition was closed.

Conclusion

This case shows how courts handle trademark disputes, especially when one party questions the validity of another’s trademark. The Madras High Court balanced the need to protect valid trademarks with ensuring a fair trial by allowing some of the petitioners’ issues but rejecting their weak challenge to the trademark’s validity. For law students and junior lawyers, this case teaches the importance of presenting strong evidence when challenging a trademark, the role of statutory time limits, and how courts decide which issues to include in a lawsuit. It also highlights the practical application of Section 124 of the Trade Marks Act in commercial disputes.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi