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Delhi High Court Permanently Bars Lubricant Maker From Using Castrol-Like Trademarks And Packaging
Ayushi Shukla
14 Nov 2025 4:50 PM IST
The Delhi High Court has permanently restrained ZRH Lubes, an automative lubricant maker from using marks such as CREMESTROL, ACTION, MADMAXX ACTION logo, and packaging, after finding them deceptively similar to Castrol Limited's registered trademarks and trade dress.The order was passed ex-parte on November 6, 2025, by Justice Manmeet Pritam Singh Arora, as ZRH failed to file a written...
The Delhi High Court has permanently restrained ZRH Lubes, an automative lubricant maker from using marks such as CREMESTROL, ACTION, MADMAXX ACTION logo, and packaging, after finding them deceptively similar to Castrol Limited's registered trademarks and trade dress.
The order was passed ex-parte on November 6, 2025, by Justice Manmeet Pritam Singh Arora, as ZRH failed to file a written statement and stopped appearing in court despite being served.
Castrol, part of the UK based BP Group, has been using the CASTROL trademark in India since 1911 and the ACTIV mark for motorcycle engine lubricants since 1999. The company told the court that its distinctive packaging, color scheme, and container shape are widely recognized by consumers.
In 2023, Castrol discovered that ZRH had applied for trademarks including CREMESTROL and MADMAXX ACTION logo for use on lubricants. Castrol opposed these applications at the Trade Marks Registry and sent a cease-and-desist notice in January 2024.
The court noted that an ad-interim injunction had already been granted on November 6, 2024, and later made absolute on September 11, 2025, stopping ZRH from using the marks while the case was ongoing.
The court found that ZRH's marks and packaging were deceptively similar to Castrol's trademarks and trade dress. Using similar marks, colors, and container shapes, ZRH could mislead consumers into thinking their products were associated with Castrol, which amounted to trademark and trade dress infringement as well as unfair competition.
“Such use amounts to infringement of the Plaintiffs' trademark, copyright, and trade dress rights. The Defendants' actions are calculated to mislead consumers into believing that their products originate from or are associated with the Plaintiffs, thereby unlawfully encroaching upon the goodwill and proprietary rights that the Plaintiffs have built through years of business and marketing efforts.”, the Court said.
The court referred to the Supreme Court's ruling in Uflex Ltd v. State of Tamil Nadu and other Delhi High Court decisions, noting that ZRH's conduct selling the infringing products while avoiding the proceedings was not bona fide.
Subsequently, the court permanently prohibited ZRH Lubes from using the infringing marks and packaging and awarded Castrol Rs 5 lakh towards legal costs.
Case Title: Castrol Limited & Ors v MR Ali Hussain Amir Ali Namdar & Anr.
Citation: 2025 LiveLaw (Del) 1500
Case Number: CS (COMM) 831/2024
For Plaintiffs: Advocates Peeyoosh Kalra, V Mohini and Udayvir Rana
Click Here To Read/Download The Order

