NEW DELHI: The Delhi High Court has dismissed a rectification petition filed by Holy Cow Foundation, holding that the trademark “PATANJALI GONYLE FLOOR CLEANER” is validly registered and does not deceptively resemble the petitioner’s mark “GAUNYLE”.
The Court concluded that the petitioner failed to establish prior and continuous use of its mark and that the presence of the well-known house mark “Patanjali” sufficiently distinguishes the respondent’s product in the marketplace. In a detailed judgment delivered on January 8, 2026, Justice Tejas Karia found serious inconsistencies in the documentary evidence relied upon by the petitioner to claim usage of “GAUNYLE” since 2013. The Court noted that invoices produced by the Holy Cow Foundation contained chronologically improbable dates, casting doubt on their authenticity and undermining the claim of prior user rights under Section 34 of the Trade Marks Act.
Rejecting the allegation of deceptive similarity, the Court observed that while “GAUNYLE” and “GONYLE” may bear some phonetic resemblance, the impugned mark must be assessed as a whole. It held that the prominent use of the well-known house mark “PATANJALI” in Patanjali Gramodyog Nyas’s product clearly indicates its source and is unlikely to confuse an average consumer of ordinary intelligence and imperfect recollection.
