INTRODUCTION

The Delhi High Court’s Division Bench delivered a significant decision in the ongoing trademark dispute between RSPL Health Pvt. Ltd. and Sun Pharma Laboratories Ltd. RSPL, the owner of the "PRO-EASE" mark used for sanitary products, sought to restrain Sun Pharma from using “PRUEASE” for its pharmaceutical goods. The case raised critical questions about the scope of trademark protection, especially where goods, though falling under the same trademark classification, serve entirely different consumer needs and markets.

LEGAL ISSUES

1. Whether Sun Pharma’s use of the mark “PRUEASE” amounts to infringement of RSPL’s registered trademark “PRO-EASE.”
2. Whether the marks are deceptively similar such that consumers might be misled, despite the distinct nature of the products.
3. Whether RSPL could claim exclusive rights preventing use of similar marks in unrelated goods categories.
4. Whether RSPL’s conduct and the evidence warranted interim relief at this stage.

BACKGROUND AND SUMMARY

RSPL Health Pvt. Ltd. has used the “PRO-EASE” mark since 2012 for sanitary products, including napkins and other menstrual hygiene goods. It holds multiple registrations in Class 5 and related classes. RSPL alleged that Sun Pharma’s adoption of “PRUEASE” for a medicine containing prucalopride, aimed at relieving constipation, was dishonest and infringed RSPL’s mark.

Sun Pharma, on its part, argued that it had independently coined “PRUEASE” by combining “PRU” (from prucalopride) and “EASE” to denote relief. It claimed bona fide use since 2017 and contended that no reasonable consumer would confuse a sanitary product with a pharmaceutical drug.

The trial court denied RSPL’s request for an interim injunction, finding that the goods were unrelated, trade channels distinct, and the potential for confusion absent. RSPL’s appeal challenged this decision.

ARGUMENTS

RSPL’s Contentions

RSPL asserted that:

• The similarity of the marks could lead to consumer confusion, especially if RSPL expanded into pharmaceuticals in the future.
• Both goods fell under Class 5, strengthening its claim of potential overlap.
• Sun Pharma’s claimed prior use lacked credible documentary support.
• Sun Pharma’s adoption of “PRUEASE” was not bona fide and aimed at trading off RSPL’s goodwill.

 TO know more about this you can follow the link below:

Sun Pharma’s Contentions

Sun Pharma maintained that:

• Its mark “PRUEASE” was derived from prucalopride and “ease,” with no intention to imitate “PRO-EASE.”
• The nature of the goods—sanitary napkins versus constipation medicine—was entirely distinct, with no shared consumer base or trade channel.
• RSPL itself had previously taken the position that sanitary and pharmaceutical products were different in proceedings before the Trademark Registry.
• The application for interim relief lacked merit given Sun Pharma’s prior and continuous use since 2017.

COURT’S ANALYSIS AND JUDGMENT

The Division Bench emphasized that appellate courts must exercise restraint when reviewing discretionary orders on interim relief, interfering only when findings are arbitrary, perverse, or contrary to settled principles.

The Court noted that:

• The products were clearly unrelated, with distinct purposes, consumer bases, and trade channels.
• There was no plausible risk of consumer confusion between a sanitary product and a medicinal preparation for constipation.
• Sun Pharma’s explanation for adopting “PRUEASE” appeared reasonable and in line with common industry practice of using chemical components in trademarks.
• RSPL’s claim of future business expansion into pharmaceuticals was speculative and did not warrant injunctive relief.
• RSPL’s omission to disclose relevant materials, including Sun Pharma’s user claims, reflected poorly on its bona fides.

Balancing all factors, the Court held that RSPL failed to demonstrate a prima facie case for injunction, that the balance of convenience favored Sun Pharma, and that RSPL had not shown irreparable harm justifying interim relief.

CONCLUSION

The Delhi High Court’s decision in RSPL v. Sun Pharma highlights the limits of trademark protection across unrelated goods. Even where marks may appear phonetically or visually similar, courts will consider the nature of the products, trade practices, and consumer perception before granting relief. The ruling affirms that rights conferred by trademark registration do not automatically extend to dissimilar goods, particularly when there is no realistic prospect of confusion. It further reiterates that interim injunctions are discretionary and will not be granted lightly, especially where the plaintiff’s case rests on conjecture or incomplete disclosure.

By- SHABADPREET KAUR