The Delhi High Court dismissed an appeal by Mountain Valley Springs India in a trademark dispute with Baby Forest Ayurveda. Justices Navin Chawla and Madhu Jain upheld denial of interim relief, allowing Baby Forest to continue operations.
NEW DELHI: The Delhi High Court dismissed an appeal by Mountain Valley Springs India, the company behind the luxury Ayurveda brand Forest Essentials, in a trademark dispute with Baby Forest Ayurveda.
A Division Bench comprising Justices Navin Chawla and Madhu Jain rejected Forest Essentials’ plea against a single-judge order from May 2024 that had denied them interim relief. The ruling allows Baby Forest to continue using its brand name for baby care products.
The Division Bench stated,
“We do not find any merit in the present appeal. The same is, accordingly, dismissed,”
Forest Essentials had claimed that Baby Forest Ayurveda had “illegally, knowingly and with malice” adopted the marks ‘BABY FOREST’ and ‘BABY FOREST–SOHAM OF AYURVEDA,’ along with a similar ‘Tree’ logo, for selling Ayurveda-based products for babies and related goods. They asserted that these marks were deceptively similar to their own trademarks, such as ‘FOREST ESSENTIALS,’ ‘FOREST ESSENTIALS-BABY ESSENTIALS,’ ‘FOREST ESSENTIALS BABY,’ and ‘LUXURIOUS AYURVEDA.’
Forest Essentials argued that it had used the “Forest Essentials” mark since 2000 and baby-related variants since 2006, claiming that Baby Forest’s branding was intended to mislead consumers and exploit their goodwill.
In contrast, Baby Forest contended that “Baby Forest” is a distinct composite mark, registered since 2020. The company maintained that the term “forest” is a common dictionary word that cannot be monopolized.
The single-judge had ruled that the word ‘forest’ is generic and that Forest Essentials could not assert dominance over part of its trademark without separately registering it.
The Division Bench emphasized that Forest Essentials could not claim exclusive rights to the word “forest” and highlighted the “anti-dissection rule,” which mandates that trademarks be evaluated as a whole rather than dissected into individual elements.
The Court determined that “Forest Essentials” and “Baby Forest” were not deceptively similar when considered in their entirety.
The Court remarked,
“While in the present case, the appellant has stated that there is proof of actual deception and confusion caused by the use of the mark by the respondents, in our view, the said evidence is to be tested at the time of final hearing of the suit,”
Senior Advocate Swathi Sukumar, along with Advocates Essenese Obhan, Neel Mason, Ayesha Guhathakurta, and Urvika Aggarwal, represented Mountain Valley Springs India.
Senior Advocate Jayant Mehta advocated for Baby Forest Ayurveda, assisted by advocates Sudeep Chatterjee, Rohan Swarup, Tanya Arora, and Aastha Verma from Singh and Singh Law Firm LLP.
Case Title: Mountain Valley Spring India Pvt Ltd v. Baby Forest Ayurveda Pvt Ltd
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