Delhi High Court Bars Hotel From Using 'Bukhara' Trademark, Grants Interim Relief to ITC
The Delhi High Court has restrained a city based hotel, Bukhara Inn, from using the name “Bukhara,” ruling that it infringed ITC Limited's well-known trademark associated with its iconic restaurant, Bukhara, at ITC Maurya, New Delhi. The order was passed by Justice Manmeet Pritam Singh Arora on November 7, 2025, in a suit filed by ITC Limited, which operates its hospitality business...
The Delhi High Court has restrained a city based hotel, Bukhara Inn, from using the name “Bukhara,” ruling that it infringed ITC Limited's well-known trademark associated with its iconic restaurant, Bukhara, at ITC Maurya, New Delhi.
The order was passed by Justice Manmeet Pritam Singh Arora on November 7, 2025, in a suit filed by ITC Limited, which operates its hospitality business under the brands ITC Hotels and Bukhara.
ITC Limited, a diversified Indian conglomerate, entered the hotel industry in 1975. Its signature restaurant, Bukhara, was launched at ITC Maurya in the late 1970s and has been a registered trademark since 1985. The Delhi High Court has previously recognized “Bukhara” as a well-known trademark.
ITC alleged that Bukhara Inn was operating hospitality services under the names “Bukhara Inn,” “Hotel Bukhara,” and “Hotel Bukhara Inn”, and was listed on travel platforms such as TripAdvisor and Yatra. ITC discovered the alleged infringement in late 2024 and issued a cease-and-desist notice in December 2024.
The hotel admitted using the name but refused to comply, claiming it referred to the city of Bukhara in Uzbekistan.
The court noted that ITC had been using the “Bukhara” mark for several decades and that its restaurant enjoys reputation both in India and abroad. It observed that the use of the same mark by Bukhara Inn constituted prima facie infringement of ITC's well-known trademark.
It found merit in ITC's submission that since the Bukhara Inn's proprietor's family name was “Bukhari” and not “Bukhara,” there was no justification for adopting ITC's established mark.
“In view of the submissions made by the learned counsel for the Plaintiffs' and the documents placed on record, it prima facie appears to this Court that the Defendant's adoption of the 'BUKHARA' mark was with full knowledge of its prior, well-known status, and is not a bona fide descriptive use. The Defendant's continued defiance despite multiple opportunities demonstrates mala fides and deliberate infringement of the Plaintiffs' statutory and proprietary rights in the 'BUKHARA' trademark.”, the Court observed.
The court found that ITC had made out a prima facie case. It granted an ad-interim injunction, restraining Bukhara Inn and its associates from operating any business under the marks “BUKHARA” or any name identical or deceptively similar to ITC's trademark. The matter will be heard next on April 14, 2026.
Case Title: ITC Limited & Anr v. Bukhara Inn
Citation: 2025 LiveLaw (Del) 1468
Case Number: CS(COMM) 1187/2025
For Plaintiff: Senior Advocate Arvind K. Nigam with Advocates Gopal Jain, Shyel Trehan, Tanmay Mehta, Suhrita Majumdar, Debjyoti Sarkar, Afzal B Khan, Sharad Besoya, Agnish Aditya, Vidhi Jain and Rohan Poddar