In a significant development, the Bombay High Court has granted an ex-parte ad-interim John Doe order in favour of Hindustan Unilever Limited (HUL), one of India’s largest consumer goods companies. The relief has been granted against unidentified individuals involved in the unauthorised manufacturing and sale of counterfeit and contraband oral care products under the well-known trademarks ‘Closeup’ and ‘Pepsodent’.
Counterfeit Goods Identified in Indore and Ranchi
HUL approached the court after finding fake and illegally imported oral care products in the markets of Indore and Ranchi during an investigation in March 2025. The company alleged that these products bore a striking resemblance to genuine items, using not only their brand names but also replicating the packaging, tradedress, and HUL’s U-logo. Additionally, contraband goods imported from Nepal were found being sold alongside these counterfeits.
High Court Finds Sufficient Evidence of Counterfeit and Infringement
Justice Manish Pitale, presiding over the matter, acknowledged the substantial evidence presented by HUL. The Court held that the materials on record clearly demonstrated that the impugned goods were counterfeit and illegally imported, which justified the grant of interim relief. Emphasising that both counterfeit and contraband goods fell within the scope of infringement, the Court stated:
Since in the present case, the products being labelled as contraband in the pleadings are goods that have been illegally imported into India for sale, mixed with such counterfeit products, the applicants are entitled to press for ex-parte ad-interim reliefs.
Court Grants John Doe Relief and Appoints Receivers
The Court, noting the balance of convenience in HUL’s favour and the potential for irreparable harm, passed an order restraining the unknown defendants from:
- Manufacturing
- Printing
- Packaging
- Distributing
Any oral care products including toothpaste, mouthwash, tooth powder, and dental creams under HUL’s trademarks or artistic works. To support enforcement, the Court appointed a Court Receiver along with Additional Special Receivers, directing them to conduct inventories and distinguish between counterfeit and contraband items during their seizure operations.
Conclusion
This John Doe order by the Bombay High Court marks a crucial step in protecting intellectual property rights and curbing the spread of counterfeit and contraband goods in Indian markets. It reinforces the judiciary’s willingness to extend strong protection to brands like HUL, even against unidentified infringers. The ruling serves as a precedent for swift and decisive action in trademark infringement cases involving public health and consumer trust. Reach out to our trademark expert from Vakilsearch for more clarity and trademark protection. Our team provides complete support for trademark registration and infringement support.
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