Jio’s Trademark Right Reaffirmed: No Free Ride on A “Well-Known” Mark

By Lucy Rana and Huda Jafri

In a significant ruling reaffirming the strength of protection afforded to well-known trademarks, the Hon’ble Bombay High Court has in a recent case held that “JIO” is a well-known mark and not a generic word that may be freely adopted or used by third parties without authorization. The trademark “JIO” has been registered in the name of Reliance Industries Limited since 2013 across several classes and enjoys exclusive statutory protection under the Trade Marks Act, 1999.

The Defendants, Asif Ahmed, Usman (Proprietor) and PDR Solutions LLC, were operating a cab service business under the name “JIOCABS” and had also registered and operated a website using the domain name www.jiocabs.com, which appeared to be deceptively similar to the Plaintiff’s registered trademark. Upon examination of the matter, the Hon’ble Bombay High Court found that a strong prima facie case of trademark infringement had been made out and accordingly granted an ad-interim injunction in favour of Reliance Industries Limited, ensuring protection of the registered trademark and granting appropriate interim relief to the owner of the impugned mark.

Background

• Reliance Industries Limited is the registered proprietor of the trademark “JIO”, with the earliest registration recorded under Class 9 in the year 2011, along with registrations under multiple other classes made subsequently.
• The Defendants in the present case were engaged in providing taxi services using a deceptively similar name incorporating “JIO”, and were operating a dedicated website with the domain name www.jiocabs.com, offering services in Delhi, Dehradun, and Mumbai.
• The Plaintiff issued a legal notice calling upon the Defendants to cease use of the impugned marks and domain name; however, the Defendants continued to operate their business under the same name.
• Subsequently, the Plaintiff filed a commercial intellectual property suit seeking relief for trademark infringement and passing off, along with an immediate restraint against the Defendants from using the impugned domain name and website.
• The Plaintiff further sought judicial intervention to restrain the Defendants from using the impugned name, mark, or artwork that was identical or deceptively similar to the Plaintiff’s trademark and original artistic work.

Claims by the Plaintiff

Reliance Industries Limited placed on record extensive documentary evidence and contended as follows:

• The Defendants were actively running their cab service business by deceptively using an identical mark, name, and domain name in order to unlawfully ride upon the goodwill and reputation of the Plaintiff.
• The Defendants had deliberately imitated the original artistic work associated with the mark and name “JIO”.
• The Plaintiff claimed that it holds valid and subsisting trademark registrations for the mark “JIO”. The word mark “JIO” is registered with effect from September 7, 2012, while the label mark comprising the term “JIO” was registered on January 24, 2013, and remains valid until January 24, 2033.
• Although the brand name “JIO” was commercially adopted and launched for digital and telecom services in 2016, the mark had already been registered earlier across various classes. The earliest registration, in Class 9, dates back to December 9, 2011. Further registrations covering services such as transport, packaging and storage of goods, and travel arrangements were secured in 2012, pursuant to which the registration certificate was issued on January 24, 2013.
• The Plaintiff is the registered proprietor of the “JIO” mark and a series of such marks with all trade variants under 14 separate trademark registrations, and at the relevant time owned at least 11 domain names incorporating the word “JIO”.
• The Plaintiff’s mark “JIO” qualifies as a well-known trademark under Section 2(1)(zg) of the Trade Marks Act, 1999, a status that has been examined and affirmed by various benches of the Hon’ble Bombay High Court.
• There existed an urgent need for judicial intervention and grant of an interim injunction restraining the Defendants from continuing use of the impugned mark and name in the course of their business.

Analysis and Legal Findings

The Hon’ble Bombay High Court, after carefully examining the material placed on record by the Plaintiff, undertaking a comparison of the rival marks, and considering the conduct of the parties, held that a prima facie case was clearly established in favour of the Plaintiff.

The Court observed that despite making certain modifications to the impugned name, the Defendants continued to use the same impugned domain name, thereby perpetuating the infringing conduct. The Court once again recognized and reaffirmed the mark “JIO” as a well-known trademark under Section 2(1)(zg) of the Trade Marks Act, 1999.

Accordingly, the Court granted ad-interim injunctive relief to the Plaintiff and restrained the Defendants from using the mark “JIO”, or any name, label, or website that is identical or deceptively similar to the Plaintiff’s mark, so as to prevent infringement of the Plaintiff’s original artistic work. The Court observed:

“The continued usage of a well-known and protected brand name would indeed cause grave injury and considering the mending of ways by the Defendants, even the balance of convenience would be in favour of grant of the ad interim relief.”[1]

Conclusion

The decision significantly strengthens the protection accorded to owners of well-known trademarks against unauthorized and deceptive use by third parties. It underscores the importance of prompt legal action in cases of trademark infringement, particularly where well-known marks are involved.

While the Court has granted temporary relief to prevent immediate harm to the reputation and goodwill of the Plaintiff, the Defendants have been directed to file their replies and legal defenses in the matter. The ruling reinforces the principle that well-known trademarks enjoy enhanced statutory and judicial protection, and that attempts to unfairly capitalize on such marks will be met with swift judicial intervention.

Priyanshi Parmar , Intern at S.S.Rana & Co. has assisted in the research of this article.

[1] Reliance Industries Limited v. Asif Ahmed & Ors., 2025 SCC OnLine Bom 3754.