Facts:
Princeton University, a world-renowned Ivy League institution in the United States, was originally established in 1746 as the College of New Jersey and became “Princeton University” in 1896. Over the centuries, it gained international reputation and became home to numerous Nobel laureates, US Presidents, judges, and other dignitaries. The University has an established presence in India through academic collaborations, student exchange programs, seminars, and enrolment of Indian students. Princeton owns registrations of the trademark “Princeton” in India under Classes 16, 25, and 41 of the Trade Marks Act, 1999.
In 2020, Princeton discovered that the Vagdevi Educational Society, based in Telangana, was running institutions under the name “Princeton” and operating a website www.princetonschoolofeducation.com. The appellant alleged that this amounted to infringement and passing off, since “Princeton” is its registered and well-known mark.
The respondents, Vagdevi Educational Society, had been in existence since 1991 and claimed that their use of the word “Princeton” was independent. They asserted that the word was coined from “Prince” and “ton” (a ton of princes/princesses to be educated), and had no connection with the Ivy League University. They also claimed to be prior users in India and denied that any consumer could confuse their local colleges with Princeton University in the US.
Procedural Background:
Princeton University filed a civil suit in 2022 (CS (COMM) 270/2022) before a Single Judge of the Delhi High Court seeking an injunction to restrain the respondents from using the mark “Princeton.” Alongside the suit, it filed an interim application under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908. On 6 September 2023, the learned Single Judge dismissed the interim injunction application. The Single Judge held that Princeton had not established actual use of its mark in India prior to 1991 and that the respondents were entitled to protection under Section 34 of the Trade Marks Act as prior users. Aggrieved, Princeton filed an appeal before the Division Bench of the Delhi High Court, challenging the order of dismissal.
Core Dispute:
The essential dispute was whether Princeton University, as a foreign entity with trademark registrations in India, could restrain Vagdevi Educational Society from using the word “Princeton” for its educational institutions in India. Key questions included: Whether Princeton’s historical and international reputation amounted to sufficient use of its mark in India.
Judicial Reasoning:
The Division Bench undertook a detailed analysis of both statutory provisions and judicial precedents.
On use of mark and prior rights: The Court referred to Section 2(2)(c)(ii) of the Trade Marks Act, 1999, which defines “use in relation to services” as making a statement about availability, provision, or performance of services. The Bench clarified that such use need not be by the proprietor alone. Newspaper reports, academic collaborations, and recognition of Princeton’s presence in India since 1911 were considered sufficient to show actual use.
On transborder reputation: The Court examined Toyota Jidosha Kabushiki Kaisha v. Prius Auto Industries Ltd. (2018) 2 SCC 1, where the Supreme Court recognised the territoriality principle but also left scope for recognition of foreign marks with strong reputation. The Bench noted that Princeton’s goodwill in India, supported by historical material, admissions of Indian students, and international recognition, distinguished it from Toyota, where there was negligible presence.
On confusion and dilution: The Bench disagreed with the Single Judge’s view that no consumer could confuse a Telangana-based college with Princeton University. The Court explained that confusion could arise not only through direct deception but also through dilution, initial interest confusion, and unfair advantage. Even if fee structures and admission modes were different, the core issue was misuse of a well-known mark for identical services (education).
On geographical significance: The respondents argued that “Princeton” was a place name in New Jersey and could not be monopolised. The Court rejected this argument, holding that while geographical names are generally not monopolised, exceptional cases exist where the name acquires distinctiveness through long use and recognition, as seen in Manipal Housing Finance Syndicate Ltd. v. Manipal Stock & Share Brokers (1996 SCC OnLine Mad 736). Princeton, through decades of global use, had become uniquely associated with the appellant.
On injunction principles: The Bench reiterated the threefold test laid down by the Supreme Court in Ramakant Ambalal Choksi v. Harish Ambalal Choksi (2024) 11 SCC 351: prima facie case, balance of convenience, and irreparable harm. Princeton, as the registered proprietor with global reputation, satisfied all three conditions. Non-interference would allow dilution and unfair advantage by the respondents.
On precedents: The Court relied on Wander Ltd. v. Antox India Pvt. Ltd. [1990 Supp SCC 727], Laxmikant V. Patel v. Chetanbhai Shah [(2002) 3 SCC 65], and Seema Arshad Zaheer v. Municipal Corporation of Greater Mumbai [(2006) 5 SCC 282], holding that appellate courts can interfere when discretion is exercised perversely or contrary to settled law.
Decision:
The Division Bench allowed the appeal. The order of the Single Judge dated 6 September 2023 was set aside. The Court restrained the respondents from opening any new institution under the mark “Princeton” or any deceptively similar mark during the pendency of the suit.
However, considering that respondents were already running existing institutions under the name for several decades, the Court directed them to file affidavits every six months disclosing receipts from those institutions. This mechanism was to ensure transparency and prevent further unfair advantage.
Law Settled:
The judgment affirms that foreign institutions with substantial reputation and trademark registrations in India are entitled to protection of their marks, even if their physical operations are limited to abroad. It recognises that use of a mark in India can be established through indirect presence, media coverage, and collaborations. The decision strengthens the concept of protection against dilution and initial interest confusion, even in the absence of direct competition. It clarifies that Section 34 protection of prior users is not automatic if the claimant can show earlier and continuous reputation in India.
Case Details:
Case Title: The Trustees of Princeton University Vs. The Vagdevi Educational Society & Ors.
Case Number: FAO (OS) (COMM) 239/2023
Neutral Citation: 2025:DHC:8654-DB
Court: High Court of Delhi
Order Pronounced On: 26 September 2025
Coram: Hon’ble Mr. Justice Navin Chawla and Hon’ble Ms. Justice Renu Bhatnagar
Disclaimer:
The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By:
Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
