Delhi High Court Temporarily Bars Sale Of FOXTEEL Hair Products Over Similarity With Bare Anatomy Trade Dress

The Delhi High Court has restrained the manufacture, sale and marketing of hair care products sold under the brand name 'FOXTEEL', holding that their packaging is deceptively similar to the 'Bare Anatomy' products of premium personal care company Onesto Labs Private Limited. Justice Tejas Karia, in an order passed on December 2, 2025, granted an ex-parte ad-interim injunction after finding that the overall look, packaging and presentation of the FOXTEEL products were likely to confuse consumers and mislead them into believing that the products were associated with Bare Anatomy. The injunction will remain in force until March 23, 2026, the next date of hearing. The court observed that the case involved what it described as “triple identity”, namely identical packaging, identical hair care products and identical online sales channels, making confusion inevitable for an average consumer. It held that the overall appearance of FOXTEEL products could easily be mistaken for Bare Anatomy products by buyers with imperfect recollection. Onesto Labs told the court that it manufactures and sells premium personal care products, including shampoos and hair serums, under the Bare Anatomy brand and is the registered proprietor of the trademark. The company said it has been using a distinctive trade dress since 2018, including specific colour combinations, bottle shapes and label layouts, and that its products are widely sold across India through online platforms such as Amazon and Flipkart. According to Onesto Labs, it discovered in early November 2025 that hair care products under the FOXTEEL brand, including anti-dandruff shampoo, anti-hair fall shampoo and hair growth serum, were being sold on platforms such as Amazon and JioMart. The company said the FOXTEEL products were packaged in bottles that were almost identical to Bare Anatomy's, with similar colours, layouts and placement of branding and product claims. The court was also shown that FOXTEEL products were being promoted alongside Bare Anatomy products on e-commerce platforms, including through sponsored listings, which further increased the likelihood of consumer confusion. Onesto Labs said it had issued a legal notice on November 3, 2025, asking the rival brand to stop using the disputed packaging and remove the listings, but received no compliance. After examining the material on record, the court held that Onesto Labs was the prior adopter and continuous user of the Bare Anatomy trade dress and had acquired significant goodwill. The court said the impugned packaging reproduced the essential, prominent and distinctive features of Bare Anatomy and that the near-identical replication showed a mala fide intent to misappropriate goodwill. The court accordingly restrained the manufacturer and sellers of FOXTEEL products from manufacturing, selling, advertising or dealing in hair care products bearing the disputed packaging or any other trade dress deceptively similar to Bare Anatomy. During the hearing, Amazon informed the court that it had already removed the identified listings of the disputed products, following which no further directions were issued against the platform at this stage. The court, however, directed JioMart to take down the specified FOXTEEL listings within 24 hours of receiving notice of the order. The matter will be heard next on March 23, 2026. Case Title: Onesto Labs Private Limited v. Manishaben Bhaveshbhai Narigara & Ors.Citation: 2025 LiveLaw (Del) 1725 Case Number: CS(COMM) 1281/2025 For Plaintiff: Advocates Kripa Pandit & Christopher Thomas For Defendants: Advocates Manas Raghuvanshi & Srishti Dhoundiyal for D-2Click Here To Read/Download Order

Delhi High Court Temporarily Bars Sale Of FOXTEEL Hair Products Over Similarity With Bare Anatomy Trade Dress

Ayushi Shukla

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Delhi High Court Temporarily Bars Sale Of FOXTEEL Hair Products Over Similarity With Bare Anatomy Trade Dress

Ayushi Shukla

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