Shri Ram Education Trust vs. SRF Foundation & Ors.

“Delhi High Court holds ‘SHRI RAM’ as a key trademark element in education sector but denies interim injunction due to delay and family lineage.”

Short Description :

The dispute involved the use of the mark “SHRI RAM” in relation to schools. Shri Ram Education Trust, which has run “The Shri Ram School” since 1988, alleged infringement and passing off against SRF Foundation, which later started schools under the same family name. Although the Court acknowledged prior use and deceptive similarity, it refused an interim injunction citing delay in filing and the shared family heritage of the name.

Facts :

- Shri Ram Education Trust has operated “The Shri Ram School” since 1988.

- SRF Foundation, also belonging to the Shri Ram family, started schools using the “Shri Ram” name in 2011–12.

- The plaintiffs alleged trademark infringement and passing off, claiming exclusive rights over “SHRI RAM” in the education sector.

- Suit was filed in 2014, nearly three years after knowledge of the defendants’ use.

Findings

- The term “SHRI RAM” is the essential and distinctive part of the mark, creating prima facie deceptive similarity.

- Plaintiffs proved prior use of the mark in relation to schools.

- However, the delay of around three years in filing weakened the case for interim relief.

- Both parties being descendants of Sir Shri Ram, the Court observed that prima facie, rights in the family name could not be claimed exclusively by one branch.

Suggestion :

- Parties may consider a coexistence arrangement or clear differentiation of branding to avoid public confusion.

- Family legacy marks should ideally be governed by a mutual settlement or family arrangement rather than prolonged litigation.

Judgement (11 May 2015 – Delhi High Court) :

- The Court acknowledged prior use and the deceptive similarity of the marks.

- Despite this, it refused to grant an interim injunction against SRF Foundation.

- Key reasons: inordinate delay by the plaintiffs in approaching the Court, and the shared family lineage of the name “Shri Ram.”

- Final rights to be determined at trial.