Bombay High Court Rules on Trademark Infringement Claim Jurisdiction

In a significant ruling, the Bombay High Court has declared that a company's registered office does not necessarily have to coincide with its major place of business when filing a trademark infringement claim. The court's decision came in response to an interim plea filed by Shree Sai Plast Pvt. Ltd., contesting a trademark infringement complaint lodged against it by Prince Pipes and Fittings Ltd.

Prince Pipes, headquartered in Goa, had initiated legal action against Shree Sai Plast, which operates from Bihar. However, Prince Pipes' principal place of business is in Mumbai, where it conducts its vital business operations. Justice Bharati Dangre presided over the case and denied Shree Sai's plea, emphasizing that the litigation was appropriately filed in Mumbai, Prince Pipes' major place of business.

In her ruling, Justice Dangre underscored that a company's principal place of business should not automatically equate to its registered office. She articulated, "The principal place of business need not be equated, every time with registered office, as the principal place of business of the company is the place wherefrom the company controls its business activities, i.e., where the centre of power of the corporate body is located."

She noted that while the significant place of business could coincide with the registered office, it is not mandatory. According to Justice Dangre, the major place of business is the hub from which all of the company's operations are managed.

The court referenced Section 134(2) of the Trademarks Act, stating that a plaintiff can file a suit where its registered office is located, its principal place of business resides, or where it voluntarily dwells or works for profit.

This ruling establishes a precedent that could have far-reaching implications for future trademark infringement cases. It offers flexibility in determining the appropriate venue for legal action and underscores the importance of considering a company's operational centre rather than solely relying on its registered office address.

The decision marks a significant development in trademark law jurisprudence. It clarifies the interpretation of relevant statutes and addresses practical challenges in determining jurisdiction for trademark disputes.