Amara Raja Energy and Mobility Limited v. Exide Industries Limited (TEMPAPO-IPD/7/2025) was decided by the Calcutta High Court on 2 April 2026 by a Division Bench comprising Justice Debangsu Basak and Justice Md. Shabbar Rashidi. The appeal arose from an interim injunction granted by a Single Judge restraining the appellant from using marks allegedly similar to the well-known “EXIDE” trademark owned by the respondent. The dispute centred on issues of trademark infringement, passing off, territoriality, and transborder reputation. The appellant contended that the injunction was improperly granted and that the respondent failed to establish the necessary threshold for interim relief. Dismissing the appeal, the Division Bench held that Exide Industries had established a strong prima facie case, supported by extensive reputation and goodwill in India. The Court reiterated that appellate interference with discretionary interim orders is limited to cases of perversity or arbitrariness, which was not present. It further held that the balance of convenience favoured the respondent and that irreparable injury would result from dilution of trademark distinctiveness if the injunction were not continued. Accordingly, the interim injunction was upheld, with the clarification that observations were prima facie and would not affect the final adjudication at trial.

ISSUE OF LAW

The appeal raised several pivotal issues in intellectual property law, particularly concerning trademarks. It examined whether the use of the mark “EXIDE” by an entity operating in a different geographical territory or dealing in distinct products amounted to trademark infringement or merely constituted the common law tort of passing off. Additionally, the case addressed the principle of territoriality in trademark law, specifically the extent to which a global trademark proprietor can prevent a local entity from using a similar mark on the basis of transborder reputation. Finally, it considered whether the plaintiff had satisfied the essential requirements for the grant of an ad interim injunction—namely, the existence of a prima facie case, the balance of convenience in its favor, and the likelihood of irreparable injury if the injunction were not granted.

FACTS

The dispute involved Exide Industries Limited as the respondent (plaintiff), a prominent Indian battery manufacturer and proprietor of the “EXIDE” trademark, and Amara Raja Energy and Mobility Limited as the appellant (defendant), another leading manufacturer of lead-acid batteries known for its “Amaron” brand. The conflict arose from the appellant’s alleged use or proposed use of marks that were claimed to be deceptively similar to the respondent’s registered “EXIDE” marks, potentially leading to consumer confusion and dilution of the respondent’s long-established brand value in the Indian market. In response, the respondent sought to restrain such use through legal proceedings. At the preliminary stage, a Learned Single Judge granted interim relief in favour of the respondent; however, the appellant challenged this order, contending that the prayers in the injunction application were not properly drafted and that the respondent had failed to satisfy the stringent threshold required for the grant of interim relief.

JUDGMENT

The Intellectual Property Rights Appellate Division dismissed the appeal and upheld the injunction, affirming the reasoning adopted by the lower court. It held that Exide Industries Limited had established a strong prima facie case for trial, noting that the “EXIDE” mark had acquired substantial reputation and secondary meaning in the Indian market. The Court further emphasized that an appellate forum should exercise restraint in interfering with the discretionary powers of a Single Judge in granting interim relief, unless such an order is shown to be palpably arbitrary or perverse. On the aspect of balance of convenience, the Court found that it tilted in favour of the respondent, as permitting Amara Raja Energy and Mobility Limited to use a similar mark during the pendency of the trial would likely cause greater harm to the established goodwill of the respondent than any inconvenience caused to the appellant by the restraint. Lastly, the Court concluded that irreparable injury would be caused to the respondent in the absence of interim relief, since trademark dilution and loss of distinctiveness are intangible harms that cannot be adequately compensated through monetary damages.

SUBSEQUENT DEVELOPMENT

The Court affirmed the impugned judgment and order passed by the Learned Single Judge in its entirety, thereby upholding the grant of interim relief in favour of Exide Industries Limited. However, it clarified that the observations made at the interim stage would not prejudice the merits of the case at trial. Accordingly, the main suit shall proceed to trial, where the respective rights and liabilities of the parties, including those of Amara Raja Energy and Mobility Limited, will be conclusively determined on the basis of full evidence.

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COURT

In The High Court At Calcutta

CASE TITLE

Amara Raja Energy and Mobility Limited vs. Exide Industries Limited

CASE NUMBER

TEMPAPO-IPD/7/2025 (with IA NO. GA-COM/1/2025, GA-COM/2/2025)

BENCH

The Hon'ble Justice Debangsu Basak And The Hon'ble Justice Md. Shabbar Rashidi

DATE OF JUDGMENT

April 02, 2026