INTRODUCTION
In the case of Reliance Industries Ltd. v. Rahul Meena, delivered by the Delhi High Court on 7th October 2026, an interim order was passed, by which it restrained the use of the registered trademark “JIO” by the websites for lottery, gaming and similar services in an unlawful manner. Justice Purushaindra Kumar Kaurav held that these websites prima facie fulfilled the requirements for being classified as a “rogue website” as defined in the case of UTV Software Communication Ltd. v. 1337X.To.Ltd. The websites were suspended, and the infringing content on the webpage that was run through Blogger was also removed.
BACKGROUND
Reliance Industries Limited petitioned the Delhi High Court on the basis that certain websites were being used unlawfully in respect of the company’s registered and famous “JIO” trade mark. The company asserted statutory and common law exclusive rights in relation to the said trade mark and further that the unauthorised use of the same could result in confusion, deception, and harm to the goodwill of the company. Reliance pointed out websites such as jiolotteryi.com, jiolotterylogin.com, jiolotterygame.com, jiolottery.club and jiolottery. store for the use of the term JIO for lottery, gaming, payment-related and allied services without the authority of the company.
It was further submitted that the websites mentioned above incorporated “JIO”, “JIO LOTTERY” and “JIO LOTTERY GAME” as their prominent identifying feature and thus created a false association with or the impression of authorisation from Reliance. It may be noted here that apart from the websites themselves the matter involved several domain name registrars for registering the websites, Google LLC that ran the Blogger platform wherein “wwwjiokbcindia.blogspot.com” was hosted and Union of India through its Ministry of Electronics and Information Technology and Department of Telecommunications.
Reliance had filed a petition for interim injunction restraining any unauthorised use of its trademark and seeking necessary action in relation to the said websites. The Court went through the websites and the contents thereof and took the help of the guidelines laid down in the case of UTV Software Communication Ltd. v. 1337X.to; 2019 SCC OnLine Del 8002, to decide whether the website was rogue or not, based on the qualitative assessment of its nature and object. On 7th October 2026, the Court restrained the principal defendant from using identical or deceptively similar marks in connection with which infringement of Reliance’s registered trademarks was done.
KEY POINTS
- The Delhi High Court banned the use of “JIO”, “JIO LOTTERY” and “JIO LOTTERY GAME”, along with other identical or deceptively similar marks, in cases where the use violated Reliance’s trademark registrations.
- The Court ordered the respective domain name registrars to block the specified websites until further notice.
- The intermediary running the Blogger website was ordered to block access to and remove the infringing webpage and its content.
- The Court followed the principle of “rogue website” as laid down in UTV Software Communication Ltd. v. 1337X.
- This case is an example of how domain names and content on the internet can be banned in cases where there is unauthorised exploitation of a registered trademark and deception of users.
ANALYSIS
On consideration of the websites and the content therein, the Court concluded that prima facie the test for the rogue website was satisfied. In considering whether or not the site qualifies as a rogue website, the method that must be used will have to be qualitative in terms of the characteristics, function and effect of the website as opposed to just a quantitative measure of the amount of infringing content on the website. The use of the registered trademark without authorisation will amount to trademark infringement according to section 29 of the Trade Marks Act, 1999. Where the website has used a well-known brand name to give the impression that there exists some sort of relationship with the trademark owner, this will amount to passing off. Any unauthorised use of a registered trademark will amount to trademark infringement as per section 29 of the Trade Marks Act, 1999. This conduct may affect the goodwill of the brand and mislead consumers into believing that the fraudulent sites are genuine.
The directions from the Court covered both the operators of the websites and the intermediaries that can block access to the websites. While the domain name registrar was directed to block the said websites, Blogger, the intermediary, was directed to block the said webpage and the infringing material therein. In addition, the domain name registrars had also been impleaded for preservation and disclosure of any details with respect to the operators of the websites and their accounts. Nevertheless, this order was interim in nature, and the suit was still pending before the Court. The observations made by the Court at this stage were prima facie in nature and not conclusive of liability.
CONCLUSION
The judgment by the Delhi High Court emphasises the need to safeguard the rights of registered trademarks in cyberspace. The case illustrates how an interim injunction on websites that misused the brand name JIO and offered lottery and gambling services could be used to curb online trademark infringement. The case also illustrates the need to identify web hosts to avoid continued abuse of the trademark.
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WRITTEN BY: DEBARATI CHATTERJEE
