Delhi High Court Rejects Godrej's Contempt Plea Over Registered Chair Designs
Photo: Photosbychalo / Pixabay
The Delhi High Court has declined to take contempt action against Geeken Seating Collection Pvt Ltd in a registered design suit brought by Godrej and Boyce Manufacturing Company Ltd (CS(COMM) 424/2024, order of 13 October 2026).
Godrej sued over seven registered designs. The court had earlier restrained Geeken from selling products identical to two of them, and Geeken had undertaken on 6 February 2025 to stop manufacturing products infringing the other five. Godrej later pointed to website listings, quotations at stores in New Delhi and Chandigarh, a November 2025 invoice and Geeken's failure to file a certified inventory. It asked for detention of Geeken's directors, attachment of property and Rs 1 crore in punitive damages.
Justice Purushaindra Kumar Kaurav held that wilful disobedience had not been shown. The undertaking covered manufacture, not sale, and the court said "such a restraint cannot now be read into the undertaking dated 06.02.2025 in contempt proceedings." Geeken's belief that it could sell existing stock was found to be bona fide, partly because it disclosed those sales at the first hearing. A caution the court issued on 1 August 2025 applied only to later conduct, and no later manufacture or sale was proved. Catalogue listings alone did not establish a sale.
The court said disobedience under Order XXXIX Rule 2A of the Code of Civil Procedure "must be conclusively established, and cannot be presumed or inferred." It voiced displeasure at the delay in filing the inventory, and LiveLaw reports Geeken was directed to file it. Godrej may pursue damages at trial and apply again if new violations come to light.
The lesson travels well. Whether a design dispute is in Delhi or before the Commercial Court in Jakarta, the wording of an undertaking matters. A promise to stop making a product is not a promise to stop selling it. Rights holders who want both should ask for both.
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