Delhi High Court Refuses Quantum Hi-Tech Injunction Against LG Over 'Quantum' Trademark

The Delhi High Court has refused to grant interim relief to Quantum Hi-Tech Merchandising Pvt. Ltd. in its trademark dispute with LG Electronics India, ruling that the company's attempt to restrain LG's use of the “Quantum” mark was undermined by its failure to disclose material informationA Division Bench comprising Justice C Hari Shankar and Justice Om Prakash Shukla upheld a 2021 Commercial Court order that had lifted an earlier injunction obtained by Quantum Hi-Tech. The Court noted that suppression of facts disentitles a party from equitable relief. Quantum Hi-Tech, incorporated in 1997, claimed to have adopted the “QUANTUM” mark in the 1990s and registered it for electronic goods. The company alleged that LG Electronics was using similar marks, including “Quantum” and “Quantum Display,” for televisions and display panels, constituting trademark infringement and passing off. In October 2021, the Commercial Court initially granted an interim injunction in favor of Quantum Hi-Tech. However, by December 2021, the court lifted the injunction after finding that Quantum had failed to disclose key information regarding its earlier trademark applications and related proceedings. Quantum then appealed to the Delhi High Court.After reviewing the case, the Division Bench agreed with the Commercial Court that Quantum Hi-Tech had not made full and fair disclosure while seeking the injunction. “No injunctive relief, under Order XXXIX Rules 1 and 2, is available to a party which approaches the Court with unclean hands. Equity inheres in Order XXXIX Rules 1 and 2.”, the bench observed relying of apex court rulings.While the Court acknowledged that Quantum Hi-Tech had a prima facie case of infringement, since LG had admitted to using marks containing the word “Quantum” for similar products, the concealment of facts barred the grant of equitable relief.Regarding the passing off claim, the Court found insufficient evidence of actual market confusion. It explained, “The very basis of a passing off tort is an attempt to pass off one's goods as the goods of another. The issue of whether a case of passing off is, or is not, made out has, therefore, to be assessed on the basis of the manner in which the defendants' goods are sold in the market. In the absence of any evidence of such sale, the learned Commercial Court, we agree, was in no position to return any positive finding on the appellant's plea of passing of.” Consequently, the High Court dismissed Quantum Hi-Tech's appeal and upheld the Commercial Court's decision, emphasizing that equitable relief is available only to parties who approach the court with clean hands. Case Title: Quantum Hi-Tech Merchandising Pvt. Ltd. v. LG Electronics India Pvt. Ltd. & Ors.Citation: 2025 LiveLaw (Del) 1443 Case Number : FAO (COMM) 22/2022 For the Appellant: Advocates Anirudh Bakhru, Vikas Khera, Sneha Sethia and Yash Sharma For the Respondents: Advocates Hemant Singh, Mamta Jha, Sambhav Jain, Sidhant Oberoi and Sanya SrivastavaClick Here To Read/Download The Order

Delhi High Court Refuses Quantum Hi-Tech Injunction Against LG Over 'Quantum' Trademark

Ayushi Shukla

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