Introduction:

In the case Reliance Industries Limited v. Pawan Kumar Gupta & Ors. [CS(COMM) 675/2025], the Delhi High Court issued significant interim relief to Reliance Industries Limited by directing major e-commerce platforms, including Amazon, Flipkart, Snapdeal, Meesho, and Indiamart, to temporarily delist the pages of 21 sellers allegedly offering counterfeit Fast-Moving Consumer Goods (FMCG) under the well-known trademarks “RELIANCE” and “JIO.” The order, passed by Justice Saurabh Banerjee, emphasized that the matter concerned edible products such as “poha,” which are regularly consumed by a wide range of Indian consumers, including those from rural and semi-literate backgrounds. In this context, the Court underlined that greater judicial caution must be exercised, especially when the misuse of trademarks could mislead vulnerable consumers and potentially compromise consumer safety.

Arguments:

The plaintiff, Reliance Industries Limited, represented by Mr. Ankit Sahni and his legal team, argued that its registered trademarks had been blatantly copied by 21 sellers who were operating under fictitious or unverifiable identities. Reliance discovered that counterfeit goods were being sold online under its brand names and logos, which had the potential to mislead unsuspecting buyers into believing they were purchasing genuine Reliance or Jio products. The brand submitted that not only were the sellers infringing its intellectual property rights, but also taking advantage of the public’s trust and goodwill associated with its names. Moreover, it stressed that such deceptive listings would particularly affect those consumers who might not be well-versed with online frauds, including semi-literate or rural populations, and therefore, judicial intervention was urgently required to curb such activities. The petitioner further submitted that the wide-scale abuse of their trademarks was enabled due to the structure of online platforms, where sellers often remain faceless or unverified, which makes post-facto legal enforcement difficult. As a result, Reliance requested the Court to restrain the infringing sellers and direct online platforms to delist the listings and provide seller information.

On the other side, counsels representing the e-commerce platforms—Indiamart (represented by Mr. Naman Joshi), another defendant (represented by Mr. Akshay Maloo), and Snapdeal (represented by Mr. Vivek Ayyagari)—did not contest the gravity of the matter but sought to clarify their platform’s intermediary status and submitted that they were willing to comply with the Court’s directions as long as their role was confined to that of a neutral marketplace. They emphasized the limitations placed on intermediaries under the Information Technology Act, 2000, and that they rely on complaints from aggrieved trademark owners to take down any infringing listings. While acknowledging the general intermediary framework under the IT Act, the Court made it clear that the platforms have a legal responsibility to not only respond to infringement notices but also assist the plaintiff and authorities in identifying and preventing repeat trademark abuse.

Judgement:

The Court held that when the subject matter concerns edible goods that are directly consumed, public safety becomes a dominant concern that outweighs the neutral intermediary argument. Justice Saurabh Banerjee observed that in such cases, the likelihood of confusion is high, especially where the consumers rely heavily on trademarks and logos to distinguish the origin of products, and there is no personal or physical verification involved in online shopping. The Court noted that the overall packaging and presentation of the defendants’ goods were strikingly similar to the original Reliance or Jio branded products and that prima facie, it appeared that the sellers had intentionally copied the marks to deceive consumers. The judge held that “it is prima facie evident that the defendant nos.1 to 21 are using the marks of the plaintiff, which makes it apparent that the defendants are guilty of imitating or copying the plaintiff’s trademarks in entirety, which the unaware customers will certainly not know of.” This finding formed the legal basis for issuing an interim injunction restraining the 21 sellers from continuing their sales. Further, the Court passed a sweeping direction to the e-commerce platforms to not only delist the infringing listings but also disclose comprehensive details of the accused sellers, including names, addresses, email IDs, phone numbers, and importantly, their bank account details, which would aid future enforcement actions and traceability. The Court held that these platforms cannot permit their marketplaces to be used as havens for intellectual property infringement or as instruments that enable counterfeit goods to circulate in the market. Justice Banerjee highlighted the growing challenges in digital commerce enforcement and remarked that when platforms enable transactions of essential consumer goods, especially food items, they must also ensure that their marketplaces are not weaponized by dishonest sellers. The balance of convenience, in this case, was found in favor of Reliance due to the nature of the infringement, the reputation of its brand, and the serious consequences of counterfeit edible goods reaching unsuspecting consumers. Consequently, the High Court adopted a “more cautious and stringent approach” to prevent any possibility of confusion or injury, both to consumers and to the brand’s longstanding market credibility. The Court fixed the next hearing date for November 13, 2025, for further proceedings, including potential framing of issues, as well as consideration of permanent injunction and damages. It was made clear that failure by any of the e-commerce platforms to comply with the directions would invite further judicial scrutiny. In this way, the Delhi High Court laid down a critical precedent on the issue of trademark protection in the online FMCG retail environment. By recognizing the potential of counterfeit products to pose a real health hazard, and acknowledging the intermediary role of platforms while still holding them to account, the Court bridged a significant enforcement gap in Indian trademark law. The decision upholds the integrity of consumer protection, affirms brand owners’ rights against digital impersonation, and sends a strong warning to online sellers misusing e-commerce infrastructure for deceptive practices. Importantly, it also brings into focus the rising responsibilities of e-commerce players to engage in proactive brand protection and due diligence in light of the increasing scale of online retail. Going forward, the outcome of the next hearing in this case will be crucial in setting a permanent precedent on how intellectual property rights are safeguarded in the fast-evolving online consumer goods market.