Delhi High Court – Orders
Singh And Singh Law Firm Llp & Anr vs Singh And Singh Chartered Accountants & … on 26 February, 2026
Author: Jyoti Singh
Bench: Jyoti Singh
$~50
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CS(COMM) 192/2026
SINGH AND SINGH LAW FIRM LLP & ANR. .....Plaintiffs
Through: Mr. Tanmaya Mehta, Mr. Kapil
Midha and Mr. Runjhun Garg, Advocates with Mr.
Karmanya Singh Sareen and Mr. Krishnagopal
Abhay, ARs of the Plaintiffs.
versus
SINGH AND SINGH CHARTERED ACCOUNTANTS & ORS.
.....Defendants
Through:
CORAM:
HON'BLE MS. JUSTICE JYOTI SINGH
ORDER
% 26.02.2026
I.As. 5345/2026, 5346/2026 (Exemption)
1. Allowed, subject to all just exceptions.
2. Applications stand disposed of.
I.A. 5347/2026 (u/S 151 CPC)
3. This application is filed on behalf of the Plaintiffs seeking exemption
from filing documents in separate volumes.
4. For the reasons stated in the application, the same is allowed
permitting the Plaintiffs to file documents in separate volumes.
5. Application stands disposed of.
I.A. 5348/2026 (u/S 151 CPC)
6. This application is filed on behalf of the Plaintiffs seeking exemption
CS(COMM) 192/2026 Page 1 of 13
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from filing the synopsis and list of dates within the prescribed limit.
7. For the reasons stated in the application, the same is allowed taking
the synopsis and list of dates on record.
8. Application stands disposed of.
I.A. 5349/2026 (for pre-institution mediation)
9. This application is filed on behalf of the Plaintiffs under Section 12-A
of the Commercial Courts Act, 2015 seeking exemption from Pre-Institution
Mediation.
10. Having regard to the facts of the present case wherein urgent relief is
prayed for and in light of the judgment of Supreme Court in Yamini
Manohar v. T.K.D. Keerthi, (2024) 5 SCC 815, as also Division Bench of
this Court in Chandra Kishore Chaurasia v. RA Perfumery Works Private
Ltd., 2022 SCC OnLine Del 3529, exemption is granted to the Plaintiffs
from Pre-Institution Mediation.
11. Application is allowed and disposed of.
I.A. 5344/2026 (u/O XI Rule 1 (4) of Commercial Courts Act, 2015 r/w
Section 151 CPC)
12. This application is filed on behalf of the Plaintiffs seeking to place on
record additional documents within 30 days.
13. Plaintiffs, if they wish to file additional documents at a later stage,
shall do so strictly in accordance with provisions of the Commercial Courts
Act, 2015.
14. Application is allowed and disposed of.
CS(COMM) 192/2026
15. Let plaint be registered as a suit.
16. Upon filing of process fee, issue summons to the Defendants through
CS(COMM) 192/2026 Page 2 of 13
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all permissible modes, returnable before the learned Joint Registrar on
23.03.2026.
17. Summons shall state that the written statements shall be filed by the
Defendants within 30 days from the receipt of summons along with affidavit
of admission/denial of the documents filed by the Plaintiffs.
18. It will be open to the Plaintiffs to file replications within 30 days from
the date of receipt of written statements along with affidavit of
admission/denial of documents filed by the Defendants.
19. If any of the parties wish to seek inspection of any documents, the
same be sought and given the timeline prescribed in Delhi High Court
(Original Side) Rules, 2018.
20. Learned Joint Registrar will carry out admission/denial of documents
and marking of exhibits.
I.A. 5343/2026 (u/O XXXIX Rules 1 and 2 r/w Section 151 CPC)
21. This application is filed on behalf of the Plaintiffs under Order
XXXIX Rules 1 and 2 read with Section 151 of CPC for grant of ex parte ad
interim injunction.
22. Issue notice to the Defendants through all permissible modes,
returnable before Court on 29.04.2026.
23. Case of the Plaintiffs, as set out in the plaint is that Plaintiff No. 1 is a
registered Limited Liability Partnership and Plaintiff No. 2 is the registered
owner of the mark ‘Singh & Singh’ in India. The name ‘Singh & Singh’ was
coined way back in 1997 by its founders and the mark has been
continuously, extensively and uninterruptedly used since then. From 1997 to
now, the Firm has grown into one of India’s largest and established firms,
especially, in the areas of Constitutional Law; Taxation, Company and
CS(COMM) 192/2026 Page 3 of 13
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Commercial matters, Intellectual Property Rights disputes, Media and
Telecommunications issues, Broadcasting, Arbitration, Competition Law,
Drugs Regulatory Laws, Education related Laws, Drug Regulatory Laws,
Internet and Cyber law disputes, Domain name disputes, Trade Secrecy laws
and other legal areas such as financial tax advisory etc.
24. It is stated that the name ‘Singh & Singh’, which is the name of the
law firm since 1997 and the corresponding trademark ‘Singh & Singh’, was
registered as a trademark in 2005 as ‘Singh & Singh Advocates’. Another
mark SINGH & SINGH was applied for trademark registration in 2009 and
the trademarks were subsequently assigned to its current proprietor i.e.,
Plaintiff No. 2 w.e.f. April, 2014. In 2011, one of Plaintiff No. 1’s founders
along with four other Advocates registered a limited liability partnership by
the name Singh & Singh Law Firm LLP. Plaintiff No. 1 is a permissive user
of these names/marks since inception and has continuously used the same
for consultation, advice and rendering legal services. Trademark
registrations in the name of Plaintiff No. 2, which are valid and subsisting
are as follows:-
25. It is stated that Plaintiff No. 2 has also filed applications for
registrations of the marks internationally, taking advantage of its global
reputation as follows:-
CS(COMM) 192/2026 Page 4 of 13
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CS(COMM) 192/2026 Page 5 of 13
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26. It is stated that Plaintiff No. 1 is currently operating with four senior
partners and five partners, each of whom is an expert in his/her respective
practice areas and includes a team of 50+ lawyers, chartered accountants,
patent agents and engineers. The firm ‘Singh & Singh’ has acquired
enormous acclaim and fame in India as also abroad and firm’s clientele hails
from different parts of the world such as USA, Canada, Japan, China,
Australia, Brazil, Singapore, Germany, Hong Kong, South Africa, Spain,
UK, amongst others. Plaintiff No. 1 has over the years grown to become a
popular firm in fields of Intellectual Property Litigation, Information
Technology, TMT and Taxation as also Technology, Media and
Telecommunication Laws. Firm has been ranked in TIER 1 and TIER 2
firm, especially, in the ‘contentious’ areas of practice for trademarks,
copyright and patents by various international and national publications,
such as Managing IP, Asia IP, WTR 1000, Legal Era, Lex Witness, Global
IP, Benchmark Litigation Asia Pacific, WIPR Leaders, Media Law
International, Business World, Iam 1000, Chambers, Corporate International
and Legal 500.
27. It is stated that Plaintiff No. 1 has been awarded and recognised on
several occasions by known publications across the world. Awards such as
Indian Firm of the Year-Trademark Contentious by Managing IP, have
been conferred on the firm. Firm’s reputation is also established from the
fact that it has earned number of accolades and the non-exhaustive
list of awards is furnished in paragraphs 16 and 17 of the plaint.
Large number of articles, write-ups, opinions and case law analysis
have been published by the firm in several international and national
magazines inter alia relating to recent developments in fields of law
CS(COMM) 192/2026 Page 6 of 13
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across the globe. The firm can boast of conducting some of the landmark
cases in the field of intellectual property as enumerated in paragraph 21 of
the plaint.
28. It is stated that Defendant No. 1 claims to be a Chartered
Accountancy Firm located at Rajouri Garden, Delhi, operating a website
under the names ‘Singh & Singh’ and ‘Singh & Singh Chartered
Accountants’ and seems to be rendering services relating to GST,
insolvency, corporate finance, company law, tax advisory etc. Defendant
No. 2 claims to be the founder and/or managing partner of Defendant No. 1.
Defendants No. 3 and 4 are partners in Defendant No. 1 firm. Plaintiffs
came across Defendants’ use of Plaintiffs’ mark/name ‘Singh & Singh’,
while preparing a brochure for its clients in relation to a query relating to
taxation services. Screenshot of the website (for the sake of anonymity,
pictures of the individuals have been removed), where Defendants are
representing themselves, is as follows:-
29. It is stated that Defendant No.1’s domain name ‘singhandsingh.in’
and Plaintiffs’ domain name ‘singhandsingh.com’ are identical. Plaintiffs
also came across a Facebook page under the name ‘Singh & Singh
Chartered Accountants’, which has only 13 followers. Screenshot of the
page is as follows:-
CS(COMM) 192/2026 Page 7 of 13
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30. It is stated that as per posts on the Facebook page, Defendants claim
user since 2002, which is false since they have no online presence till 2014.
CS(COMM) 192/2026 Page 8 of 13
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Assuming that the claim is correct, Plaintiffs’ user dates back to 01.01.1997
and therefore, it is evident that Defendants were consistently aware of
Plaintiffs’ mark and their stellar reputation. In fact, Defendants’ Facebook
page (https://www.facebook.com/p/Singh-singh-chartered-accountants-1000
68315047364) also uses Plaintiffs’ mark illegally and passes itself off as a
page of or associated with the Plaintiffs.
31. Learned counsel for the Plaintiffs submits that name ‘Singh & Singh’
was registered in India in 2005 for legal services and the user dates back to
1997. The name ‘Singh & Singh’ of the Plaintiffs and ‘Singh & Singh
Chartered Accountants’ used by the Defendants are identical/deceptively
similar to each other and are used for overlapping services. The use of
‘Singh & Singh’ in the domain name by Defendants adds to the infringing
conduct of the Defendants. The name ‘Singh & Singh’ has acquired
distinctiveness in course of trade and is solely attributable to and associated
with Plaintiff No. 1 and no one else. It is obvious that Defendants are using
‘Singh & Singh’ to ride on the goodwill and reputation of Plaintiff No. 1,
which it has garnered over the years, both in India and internationally.
Defendants’ unauthorized use of the impugned mark will inevitably lead to
confusion amongst clients/potential clients. The impugned marks are used
by Defendants on their website and other social media platforms and are
clearly visible and accessible through interactive webpages.
32. It is urged that Defendants in response to Plaintiffs’ legal notice dated
04.02.2026 stated that the suffix ‘CHARTERED ACCOUNTANTS’ was a
professional defining and there was no cause of any confusion, however,
they have conveniently dropped the suffix in the domain name
singhandsingh.in, thereby effectively cloning Plaintiffs’ domain name and
CS(COMM) 192/2026 Page 9 of 13
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this is nothing but a bad faith adoption with mala fide intent of diverting
Plaintiffs’ clientele. Further, Defendants sought to place reliance on the anti-
dissection rule, stating that the expression ‘Singh & Singh Chartered
Accountants’, when seen as a whole has no deceptive similarity. This
response is misconceived, to say the least. The rule does not permit any
party to appropriate the dominant and source-identifying element of a mark
and avoid liability by banking on a descriptive matter. In M/s. South India
Beverages Pvt. Ltd. v. General Mills Marketing Inc. & Anr., 2014 SCC
OnLine Del 1953, this Court held that action against infringement cannot be
avoided merely because the competing mark is not a complete reproduction
of the registered mark, if the essential features are adopted.
33. Having heard learned counsel for the Plaintiffs and upon perusal of
the documents as well as the rival marks, I am of the view that Plaintiffs
have made out a prima facie for grant of ex parte ad interim injunction
against Defendants. Balance of convenience lies in favour of the Plaintiffs
and they are likely to suffer irreparable harm in case the interim injunction,
as prayed for, is not granted.
34. From a perusal of the documents and the competing marks, I am of
the prima facie view that the impugned marks ‘Singh & Singh’ and ‘Singh
& Singh Chartered Accountants’ are identical/deceptively similar to
Plaintiffs’ registered marks/names ‘Singh & Singh’ . Plaintiffs
operate their official website under the domain name ‘singhandsingh.com’
and Defendants have incorporated the dominant portion and trade identifier
of the Plaintiffs’ trademark in their domain name ‘singhandsingh.in’, having
only altered the Top-Level Domain, which is inconsequential to an average
CS(COMM) 192/2026 Page 10 of 13
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customer/internet user exercising ordinary caution. Defendants’ wesbite
expressly uses the term ‘Pleadings, appeals’, ‘Litigation’ and ‘Prosecution’
offering consultancy on income tax matters, regulatory compliances, filings
etc., which squarely fall within the ambit of legal services and hence prima
facie the competing services overlap. As brought forth in the plaint,
Defendant No. 2 openly advertises services on professional networking
platforms, including LinkedIn using very specific keywords such as
‘Bankruptcy Law’, ‘Corporate Law’, ‘Tax Law’, ‘Business Law’, ‘Company
Law’ and ‘Labour Laws’, while also using identical name ‘Singh & Singh’
and this reinforces the impression that Defendants form part of the Plaintiffs
and/or are associated with them in some manner. It is settled that to trigger
the doctrine of Initial Interest Confusion, it is sufficient if impugned use
captures consumer’s attention by creating an association at the threshold
stage albeit later the consumer may realise the distinction. In Google LLC v.
DRS Logistics (P) Limited and Others, 2023 SCC OnLine Del 4809, this
Court considered the concept of Initial Interest Confusion in the context of
infringement by using keywords and domain names and held as follows:-
“156. The doctrine of “initial interest confusion” has been applied where
the courts have found material confusion albeit at an initial stage,
resulting from the display of the use of meta tags, keywords and domain
names for reflecting results which are identical or similar to registered
trade mark. In cases, where the internet users are deceived, to access the
websites other than the websites offering goods, services and information
as may be associated with the trade mark, the use of the trade mark in
internet advertising may be actionable.
xxxx xxxx xxxx
162. Under Section 29(2) of the TM Act, a registered trade mark is
infringed by a person who not being a registered proprietor or a person
permitted to use the same, uses the mark which is identical or similar to
the registered trade mark in respect of goods “which is likely to cause
confusion on the part of public or which is likely to have an association”
CS(COMM) 192/2026 Page 11 of 13
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with the registered trade mark. Section 29 of the TM Act does not specify
the duration for which the confusion lasts. The trigger for application of
Section 29(2) of the TM Act is use of a mark, which would result in
confusion or indicate any association with the registered trade mark. Thus,
even if the confusion is for a short duration and an internet user is able to
recover from the same, the trade mark would be infringed. Once the
applicability of Section 29(2) of the TM Act is triggered, it would be no
defence to state that the interest user was not deceived in entering into the
transaction and/or in fact, did ascertain that there was no association of
the advertiser or its goods with the trade mark.”
35. In the case of Under Armour Inc. v. Anish Agarwal and Another,
2025 SCC OnLine Del 3784, this Court addressed the immense threat of
damage to potential clientele of a bona fide user by capturing their attention
for a moment and held as follows:-
“94. It is apparent that the aforesaid view does not align with the concept
of Initial Interest Confusion Test. The Initial Interest Confusion Test
recognizes that confusion in the minds of the customers arises only at the
stage prior to consummating the purchase. However, at the time of
completing the transaction, there is no doubt in the customer’s mind
regarding the origin of the goods. The confusion, albeit limited to the
initial stage, is sufficient to satisfy the condition of deceptive similarity as
contemplated in Section 29 of the TM Act. In some cases – particularly,
when the senior trademark is a famous or a well-known mark – it may
serve the infringer’s purpose merely to capture the customer’s attention.
The customer may eventually choose the infringer’s product based on its
qualities and attributes, fully aware that it has no association with the
registered trademark.”
36. It is pertinent to note that several orders have been passed by this
Court previously, granting ex parte ad interim injunction in favour of the
Plaintiffs as also final decrees of permanent injunction protecting the
registered marks, details of which are furnished in the plaint and the copies
of the orders have been filed along with the plaint.
37. In light of the aforesaid facts and the settled law, till the next date of
hearing, Defendants, their promoters, associates, family members,
employees and anyone acting for and on their behalf, are restrained from
CS(COMM) 192/2026 Page 12 of 13
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using the impugned marks ‘Singh & Singh’ and ‘Singh & Singh Chartered
Accountants’ and/or any other trademark/trade name/trading style/domain
name including domain name https://www.singhandsingh.in/, Facebook
profile/page, twitter handle, LinkedIn profile/page, advertisements, social
media promotions, logo or device etc., which are identical to or deceptively
similar to Plaintiffs’ mark ‘Singh & Singh’ or any derivate or variant
thereof, amounting to infringement and/or passing off and dilution.
38. Defendants are directed to take down/delete/remove the infringing
content containing the impugned marks and/or any mark deceptively similar
to Plaintiffs’ mark ‘Singh & Singh’ and/or any variant thereof from their
website and all other platforms including social media platforms, within 72
hours of receipt of this order.
39. Plaintiffs shall comply with the provisions of Order XXXIX Rule 3
CPC within a period of two weeks from today.
JYOTI SINGH, J
FEBRUARY 26, 2026/RW
CS(COMM) 192/2026 Page 13 of 13
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