Introduction
In a striking courtroom face-off, Travel Blue Products India Private Limited & Travel Blue Limited v. Miniso Life Style Private Limited & Miniso Hong Kong Ltd., the Bombay High Court weighed in on allegations of design infringement and passing off. At the heart of the dispute was Travel Blue’s registered “Tranquility Neck Pillow,” a travel essential with a distinctive look that had been protected under India’s Designs Act since 2016 (with priority from 2015) and remains enforceable until 2030.
Travel Blue, a global player in travel accessories, discovered in 2024 that Miniso was selling neck pillows uncannily similar to its own, right down to the colour combination. Upon a prima facie comparison, the Court noted a “striking overall similarity” between the two products and concluded that Miniso’s version was an unmistakable imitation, amounting to misrepresentation.
The verdict?
A swift interim injunction stopping Miniso from manufacturing or selling the infringing pillows.
Key Legal Questions Before the Court
The Court tackled three pivotal questions:
- Could Travel Blue claim a monopoly over the Tranquility Neck Pillow’s design?
- Was the design registrable, or was it purely dictated by function?
- Was the design genuinely novel?
On all counts, the answers favoured Travel Blue. The Court held that the rival designs were clear imitations. Travel Blue’s design was found to be distinctive and aesthetically appealing, with no utilitarian functionality that could bar registration. Emphasizing Travel Blue’s continuous use of the design for over nine years, the Court also noted Miniso’s mala fide intent in adopting an identical design, thereby supporting the grant of interim relief.
Why Does This Ruling Matters for Design Protection?
This case reaffirms that under Indian law, design protection is centered on the overall visual impression rather than functional aspects, and that courts are willing to grant robust interim relief against clear instances of imitation, even when the competing products are marketed under different brand names.
Author: Akshi Seem, Associate Partner