In the recent landmark case of Sir Ratan Tata Trust and Anr v Dr Rajat Shrivastava and Ors, the plaintiffs, Sir Ratan Tata Trust and Tata Sons Private Limited, sought a permanent injunction against the defendants for unauthorised use of their trademarks and the well-known name of the late Sir Ratan Tata. The plaintiffs claimed that that there had been infringement of registered trademarks, copyright violations, passing off, dilution of goodwill and personality rights violations.
The Sir Ratan Tata Trust, founded in 1919, is a part of the respected Tata Trusts charitable group and has a longstanding reputation in philanthropy. The second plaintiff, Tata Sons, is the principal promoter and investment holding company of the Tata Group, which owns the globally recognised trademark Tata. The plaintiffs had registered the trademark Tata and its derivatives and the mark Tata Trusts in various forms.
The first defendant was a journalist and founder of the Delhi Today Group. He and the other defendants had promoted the Ratan Tata National Icon Award 2024, misusing the plaintiffs’ trademarks and Sir Ratan Tata’s name. The plaintiffs alleged that the defendants had deceived the public to solicit nomination fees. The defendants also publicised the unauthorised event on their websites and social media accounts.
The plaintiffs sent a notice to the defendants in December 2024, demanding the removal of the misleading content. Although some posts were taken down, the defendants promoted a similar event, the Ratan Tata National Icon Award 2025 and the India Visionary Leaders’ Summit 2025 to be held in February 2025 at a prestigious venue in New Delhi.
Responding to the continued infringements, the plaintiffs publicly dissociated themselves from the event and sent a notice to the defendants. The plaintiffs confirmed the misuse by sending agents to investigate. Despite this, the defendants continued to confuse and deceive the public by announcing a list of awardees.
The plaintiffs contended that the defendants were syphoning off the public’s money through untraceable means, further damaging their goodwill and reputation through an illusion of association with Tata Trusts. The plaintiffs provided evidence that individuals supposedly honoured at the event expressed gratitude to the Tata Trusts, believing they were affiliated with the awards. The plaintiffs argued the defendants had knowingly infringed the group’s intellectual property and the personality rights of the late Sir Ratan Tata.
Delhi High Court found that the plaintiffs had presented sufficient evidence to support their case, showing that the defendants had advertised the unauthorised event on various online platforms, using the Tata brand name and even Sir Ratan Tata’s photograph. The court held that the Tata trademark had long been established as a well-known mark and was protected under the Trade Marks Act, 1999. Because of his great contribution to business and philanthropy, Ratan Tata’s name also held substantial public recognition and goodwill.
The court cited the case of Arun Jaitley v Network Solutions Private Limited and Ors, which held that a personal name is distinctive because of the popularity of the person and is entitled to legal protection under trademark laws. The judgment also cited the United States case of Martin Luther King Jr. Center for Social Change v American Heritage Products, which affirmed that the right of publicity survives the death of an individual and can be inherited or assigned.
The court had little trouble in ruling in favour of the plaintiffs. It held that the name of Sir Ratan Tata was a well-known personal name and mark, entitled to protection from unauthorised use. The court granted a permanent injunction, restraining the defendants from using the trademarks Tata or Tata Trusts, the logo of the plaintiffs, and the name or photograph of Sir Ratan Tata in any manner.
This landmark judgment of Delhi High Court is significant because it protects well-known trademarks and the personality rights of individuals, even after their death. It protects the personality rights of individuals from misuse that may tarnish their legacy. The court recognised that individuals and organisations with established goodwill and recognition have the right to prevent misuse of their identities for deceptive commercial gains.
