Delhi High Court Temporarily Injuncts Sale Of Copycat “Little Hearts” Biscuits In Relief To Britannia
The Delhi High Court has granted an ad-interim injunction in favour of Britannia Industries Limited, restraining Shri Swastik Organics and its associates from manufacturing, selling or marketing biscuits under the name “Little Hearts” or using an identical heart-shaped biscuit design.
The court found that the rival manufacturer had adopted the mark and product design in a clear and deliberate act of dishonesty. The injunction will continue until further orders.
In an order passed on December 23, 2025, Justice Manmeet Pritam Singh Arora held that the disputed products were virtually identical to Britannia's “Little Hearts” biscuits. The court noted that the name, the shape of the biscuit, and the trade channels were the same, and that the sale of such products was likely to mislead consumers.
Britannia told the Court that it has used the mark “Little Hearts” since 1988 and launched its distinctive sugar-coated, heart-shaped biscuits in 1993. It said it holds trademark registrations for the “Little Hearts” word mark as well as the three-dimensional shape of the biscuit. The company also placed its sales figures on record to show substantial revenue and goodwill associated with the product.
According to Britannia, it discovered in December 2025 that biscuits bearing the identical name “Little Hearts” and the same heart-shaped design were being sold on Amazon. After purchasing the product, the company found that Shri Swastik Organics and its associates were acting together in selling the disputed goods.
Britannia pointed out that the online listings did not merely copy the name and shape. The descriptions expressly referred to “Britannia Little Hearts” and to a “trademark gold and red pack.” The listings also displayed images of Britannia's original product, over which the company claims copyright.
After comparing the competing products, the court found that both the mark and the biscuit shape used by the defendants were identical to Britannia's registered trademarks. It held that the case involved “triple identity,” namely identical marks, identical products and identical trade channels aimed at the same consumers. The court observed that an average consumer, with imperfect recollection, was likely to assume an association with Britannia.
Holding that Britannia had made out a strong prima facie case, the Court said that denial of interim relief would cause irreparable injury. It also found that the balance of convenience was clearly in the company's favour.
The court therefore restrained Shri Swastik Organics and its associates from using the “Little Hearts” mark or shape, or any other identical or deceptively similar mark, and from dealing in images in which Britannia holds copyright. Amazon was directed to take down all infringing product listings from its platform.
The matter will next be listed before the Court on May 21, 2026.
Case Title: Britannia Industries Ltd v. Shri Swastik Organics & Ors.
Case Number: CS(COMM) 1393/2025
For Plaintiff: Advocates Sagar Chandra, Ishani Chandra, Shubhie Wahi, Sanya Kapoor and Mansha Bhatia