Delhi High Court rejects Forest Essentials appeal in trademark dispute against Baby Forest

The Delhi High Court on Friday dismissed an appeal filed by Mountain Valley Springs India, the company behind the luxury Ayurveda brand Forest Essentials, in a trademark dispute against Baby Forest Ayurveda [Mountain Valley Spring India Pvt Ltd v. Baby Forest Ayurveda Pvt Ltd].

A Division Bench of Justices Navin Chawla and Madhu Jain today rejected the plea filed by Forest Essentials against a single-judge's order of May 2024 denying them interim relief.

Today's ruling allows Baby Forest to continue using its brand name for baby care products.

"We do not find any merit in the present appeal. The same is, accordingly, dismissed," the Division Bench has said.

Forest Essentials had approached the High Court stating that Baby Forest Ayurveda has "illegally, knowingly and with malice", adopted the marks ‘BABY FOREST’ and ‘BABY FOREST–SOHAM OF AYURVEDA’ as well as a similar ‘Tree’ logo for selling ayurveda based products for babies and other allied goods.

It was their case that these marks are deceptively similar to Forest Essentials' ‘FOREST ESSENTIALS’, ‘FOREST ESSENTIALS-BABY ESSENTIALS’, ‘FOREST ESSENTIALS BABY’ and ‘LUXURIOUS AYURVEDA’ trademarks.

Forest Essentials claimed it had been using the “Forest Essentials” mark since 2000 and baby-related variants since 2006. It alleged that Baby Forest’s branding was designed to mislead consumers and ride on its goodwill.

However, Baby Forest maintained that “Baby Forest” was a distinct composite mark, registered since 2020. It argued that the word “forest” is a common dictionary term that cannot be monopolised.

In his order, the single-judge held that the word 'forest' in itself is generic and that Forest Essentials could not claim dominance over a part of its trademark without registering the part separately.

The Division Bench has now said that Forest Essentials could not claim exclusive rights over the word “forest” and emphasised the “anti-dissection rule”, which requires trademarks to be assessed as a whole rather than broken into individual components.

The Court found that “Forest Essentials” and “Baby Forest” were not deceptively similar when viewed in their entirety.

"While in the present case, the appellant has stated that there is proof of actual deception and confusion 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," the Court added.

Senior Advocate Swathi Sukumar with Advocates Essenese Obhan, Neel Mason, Ayesha Guhathakurta and Urvika Aggarwal appeared for Mountain Valley Springs India.

Senior Advocate Jayant Mehta represented Baby Forest Ayurveda. He was assisted by advocates Sudeep Chatterjee, Rohan Swarup, Tanya Arora and Aastha Verma of Singh and Singh Law Firm LLP.

[Read Judgment]