Date: September 26, 2025
Citation: 2025 SCC OnLine Del 6296
Bench: Navin Chawla and Renu Bhatnagar, JJ.
Introduction
In Trustees of Princeton University v. Vagdevi Educational Society, the Delhi High Court ruled in favour of protection of reputed foreign trademarks in India – even without their physical presence within the territory. The Court partly allowed Princeton University’s appeal against the Single Judge’s refusal to grant an injunction restraining a Telangana-based society from using the mark “PRINCETON” for educations services.
The Division Bench recognized Princeton University’s prior use, goodwill, and reputation in India but denied a blanket injunction, noting the respondent’s long-standing use of the mark since 1991. However, the Court restrained the respondent from using the mark “PRINCETON” or any deceptively similar name for establishing new institutions during the pendency of the suit.
Facts
Princeton University (“Princeton/ Princeton University”), a globally renowned Ivy League institution founded in 1746, owns and uses the trademark “PRINCETON” in connection with its educational services and website Princeton.edu. The University claimed extensive goodwill and reputation in India due to its engagement with Indian students over decades.
The respondent, Vagdevi Educational Society (“Vagdevi”), runs schools and colleges in Telangana under the name “Princeton”. It claimed to have adopted the name in 1991 as a creative combination of “Prince” and “ton,” referring to a place for education. Vagdeviargued that “Princeton” was a geographical term (Princeton, New Jersey) and hence not exclusively protectable.
The Single Judge had dismissed Princeton University’s plea for an injunction, holding that the University had not established use of the mark in India. Princeton appealed against this order before the Division Bench.
Court’s Analysis
The Division Bench held that the Single Judge erred in concluding that Princeton University had not shown use of its mark in India. The Court clarified that “use” includes use through advertisements, digital platforms, or by third parties. Physical presence in India is not a prerequisite for asserting trademark rights.
The Court found that Princeton University had built substantial goodwill and reputation among Indian students who regularly applied to and studied at the University. This, the Court said, established a commercial presence in India sufficient to invoke trademark protection. The Bench reiterated that a proprietor with reputation and goodwill in India, whether or not physically present, is entitled to the same protection as a domestic trader.
Rejecting Vagdevi’s claim that Princeton had used the mark in India only since 1996, the Court accepted evidence showing use dating back to 1911 – confirming Princeton as the prior user. The Court also dismissed the argument that Princeton was estopped from asserting an earlier date of use.
In relation to Vagdevi’s contention that the University’s registration was obtained with consent from “Princeton Academy, Mumbai,” the Court held that a trademark owner is not required to sue every infringer. The Court relied upon the famous principal applied in the case of Shri Pankaj Goel v Dabur India 2008 (38) PTC 49 (Del) (DB) that one infringer cannot rely on inaction against another.
On the issue of similarity, the Court observed that even if the parties’ logos and designs differ, the word mark “PRINCETON” remains the dominant and distinctive element. As both entities operate in the education sector, the concurrent use of the same name could mislead consumers. The Court found that variations in logos or target demographics were insufficient to avoid confusion.
However, while Princeton established prior rights and reputation, the Court considered equitable factors relevant to interim relief. It noted that the respondent had been using the name “Princeton” since 1991, well before the University entered the Indian market, and that its operations were confined to Telangana. Princeton, on the other hand, had no physical presence in India. These factors affected the balance of convenience and the likelihood of irreparable harm, justifying only limited relief.
Accordingly, the Division Bench set aside the Single Judge’s order and partly allowed Princeton University’s appeal. The Court restrained the respondent Vagdevi from using the mark “PRINCETON” or any deceptively similar mark for establishing new institutions or societies, but did not prohibit its continued use for existing institutions. This limited injunction, the Court observed, balanced Princeton’s proprietary rights with Vagdevi’s long-standing use. It ensured that while Princeton’s goodwill was recognized, the respondent’s established educational operations were not unduly disrupted.
Significance
This judgment is a key precedent for foreign institutions seeking to protect well-known marks in India. It reaffirms that transnational reputation, i.e., goodwill established abroad but recognized by Indian consumers, is protectable under Indian law even without physical operations. The ruling clarifies that “use” under the Trade Marks Act includes online and promotional activities, not just physical or commercial transactions in India. It further confirms that dominant elements within composite marks can be independently protected where confusion is likely.
Equally important is the Court’s emphasis on equity in granting interim relief. Factors such as delay, territorial limitation, and long-standing use can influence whether full injunctions are appropriate. This ensures that enforcement remains fair and proportionate, balancing rights of foreign proprietors with bona fide local users.
Conclusion
The Delhi High Court’s decision in Trustees of Princeton University v. Vagdevi Educational Society strikes a pragmatic balance between protecting global brand reputation and respecting local enterprise. The Court affirmed Princeton University’s prior use and transnational goodwill in India while denying overbroad relief due to the respondent Vagdevi’s established, localized use.