INTRODUCTION

Trademark disputes frequently involve complex legal questions, especially when multiple parties claim rights over identical or similar marks. The case of Quantum Hi-Tech Merchandising Pvt. Ltd. v. LG Electronics India Pvt. Ltd. & Ors. FAO (COMM) 22/2022, CM APPLs. 6363/2022 & 26546/2022” In this case, Quantum Hi-Tech Merchandising Pvt. Ltd. (QHMPL) sought an interim injunction to restrain LG from using the marks “QUANTUM” and “QUANTUM DISPLAY” for its electronic products, claiming infringement and passing off. The Delhi High Court’s judgment not only evaluated the legal merits of Quantum Hi-Tech Merchandising Pvt. Ltd. (QHMPL’s) claims but also scrutinized the conduct of the parties, particularly in relation to material concealment. The ruling underscores essential components of trademark law—such as the requirement to establish a prima facie case, the significance of honest disclosure, and the limits of equitable remedies. This introduction sets the foundation for a deeper analysis of the procedural background, factual matrix, court findings, and broader implications arising from this decision.

PROCEDURAL POSTURE

The case, numbered “FAO (COMM) 22/2022 CM APPLs. 6363/2022 & 26546/2022,” came before the High Court of Delhi, presided over by Justices C. Hari Shankar and Om Prakash Shukla. The court reserved its judgment on October 30, 2025, and pronounced its verdict on November 4, 2025. The appeal arose from a lower court's decision by the District Judge (Commercial Court-II) in Shahdara, which had dismissed QHMPL’s application for an interim injunction against LG Electronics, allowing the respondents' application under Order XXXIX Rule 4 of the Civil Procedure Code (CPC).

BACKGROUND AND FACTS

QHMPL has been using the mark "QUANTUM" since 1992, prior to its assignment in 2006. The company holds registrations for a device mark featuring "QUANTUM" in Class 9, which pertains to computer hardware and accessories. Conversely, the LG group has utilized and sought registrations for various marks incorporating "QUANTUM," including "QUANTUM DISPLAY," "SMART QUANTUM," and others. In its appeal, QHMPL sought to restrain LG Electronics from using the terms "QUANTUM" and "QUANTUM DISPLAY" in connection with televisions and related products. Importantly, the appellant limited its request to these specific terms, distinguishing it from LG's other composite marks.

RELIEFS SOUGHT

The relief sought by QHMPL included:

·         A permanent and interim injunction to restrain LG Electronics from using "QUANTUM" and "QUANTUM DISPLAY" for televisions, displays, and allied goods.

·         Ancillary reliefs for passing off, damages, and a detailed account of profits.

IMPUGNED ORDER FROM THE COMMERCIAL COURT

The lower court dismissed QHMPL’s application for an interim injunction and allowed LG Electronics’ application to vacate the ad interim order. The key reasons included:

·         Lack of maintainable infringement claims regarding goods used by LG.

·         Any claims pertained to passing off rather than infringement.

·         Absence of evidence showing LG’s commercial use of "QUANTUM" or "QUANTUM DISPLAY."

·         Alleged material concealment by QHMPL regarding its trademark registrations and prior claims.

ISSUES BEFORE THE HIGH COURT

The High Court was tasked with determining:

·         Whether QHMPL was guilty of material concealment that would prevent them from obtaining equitable interim relief.

·         Whether a prima facie case of trademark infringement was established by QHMPL.

·         Whether a prima facie case of passing off was made out by the appellant.

·         Whether the impugned order warranted appellate interference.

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HOLDINGS

Material Concealment

The High Court concluded that QHMPL had indeed suppressed material facts, most notably the discrepancy regarding its application for a device mark, which erroneously received a word-mark registration. This concealment of critical information undermined QHMPL’s claim for interim relief.

Infringement Analysis

The court identified that QHMPL held a valid device mark featuring "QUANTUM" as a dominant element. LG's admitted usage of "QUANTUM" and "QUANTUM DISPLAY" since 2015 suggested a potential prima facie case for trademark infringement. However, due to QHMPL’s lack of clean hands, relief was ultimately denied.

Passing Off

Regarding passing off, the court determined that QHMPL did not provide sufficient evidence of LG’s commercial sales or market presence under the disputed marks. The absence of substantial proof of goodwill predating LG’s usage led the court to dismiss the passing off claims.

COURT'S REASONING

Material Concealment and Equitable Relief

The court emphasized the "clean hands" doctrine, which dictates that a party seeking equitable relief must act fairly and honestly in all aspects of the case. QHMPL’s failure to disclose the Registration Board’s mistake—mischaracterizing its device mark as a word-mark—was pivotal in denying the injunction. Additionally, the inconsistency demonstrated in QHMPL's affidavit against Quantum USA, where it underestimated similarity to downplay its exclusivity claims, weakened its position.

Infringement Analysis

While recognizing that a valid device mark existed, the court highlighted that the concealment of material facts warranted a refusal to grant any interim relief. The court further applied the dominant part principle and acknowledged that QHMPL’s "QUANTUM" mark had a conceptual relationship with LG's products. However, LG’s prior use in commerce and lack of evidence demonstrating QHMPL’s exclusivity ultimately decided the case against granting relief.

Passing Off

The claim for passing off hinged on the establishment of misrepresentation. QHMPL’s inability to show evidence of LG's use of the disputed marks in India, nor sufficient goodwill, resulted in failure to satisfy the criteria for establishing a prima facie case.

CONCLUSION

The ruling in “Quantum Hi-Tech Merchandising Pvt. Ltd. v. LG Electronics India Pvt. Ltd. FAO (COMM) 22/2022 CM APPLs. 6363/2022 & 26546/2022,” serves as an important precedent in Indian trademark jurisprudence, particularly concerning equitable relief and the duty of candour. Despite holding a valid device mark featuring “QUANTUM,” QHMPL’s claim for an interim injunction faltered due to material concealment and inconsistencies in its disclosures. The Delhi High Court reaffirmed that litigants seeking equitable remedies must approach the court with clean hands and complete transparency. This decision emphasizes that trademark protection extends beyond mere registration—it demands responsible enforcement, truthful representation, and substantial evidence of goodwill and prior use. For businesses, the case highlights the importance of diligent trademark management and the risks associated with misinformation in legal proceedings. Ultimately, the judgment reflects the judiciary’s balanced approach in safeguarding trademark rights while preventing misuse of the legal process.