New Delhi: The Delhi High Court has ruled in favour of Hindustan Unilever Limited (formerly Hindustan Lever Limited) and a subsidiary of Procter & Gamble in a trademark infringement case involving the manufacture and sale of counterfeit fast-moving consumer goods (FMCG). The court awarded damages of ₹2.5 lakh against individuals found to be involved in the illegal operation.
According to a report by LiveLaw, the judgment was delivered on February 28, 2026 by Justice Tejas Karia.
In its ruling, the court held that the defendants had engaged in large-scale counterfeiting of widely recognised consumer products, including shampoos, creams and detergents, using the registered trademarks of the plaintiffs. The court also found that the defendants had copied the artistic packaging and design elements associated with the brands, thereby infringing copyright protections as well.
The case was filed against Rakesh Goyal and members of his immediate family, who were accused of manufacturing, filling, packaging and selling counterfeit goods under well-known brand names. The court noted that police raids conducted in 2002 and 2003 had resulted in the seizure of substantial quantities of counterfeit products from the defendants’ premises.
The plaintiffs had sought a permanent injunction restraining the defendants from dealing in counterfeit goods bearing trademarks such as Sunsilk, Clinic Plus, Lakme, Pond’s, Ariel and Head & Shoulders. They argued that these brands are part of their widely distributed FMCG portfolios across India and that their packaging designs qualify as original artistic works protected under copyright law.
While exact sales figures of the counterfeit products were not available, the court relied on the volume of goods seized during the police operations to conclude that the plaintiffs had suffered financial losses due to the infringing activities.
Although the defendants initially contested the allegations and filed a written statement, they later stopped appearing in court and failed to cross-examine the plaintiffs’ witnesses or produce supporting evidence. As a result, the court held that the claims of trademark infringement, copyright infringement and passing off had been established.
The court directed Rakesh Goyal and two other defendants to jointly and severally pay damages of ₹2.5 lakh within four weeks. If the amount is not paid within that period, it will attract interest at the rate of 9% per annum from the end of the four-week window until payment is made.
In addition to damages, the court also allowed the plaintiffs to recover the actual costs of litigation, citing the scale of counterfeit goods seized, the continuation of the illegal activity despite earlier police action and the defendants’ absence during the later stages of the proceedings.
