In a recent trademark dispute before the Madras High Court, the petitioner, Sri Ramachandra Educational and Health Trust (SREHT) secured an interim injunction to prevent Dr. Babasaheb Ambedkar Vaidyakiya Pratishthan Sanchalit (BAVPS) from using the mark “Shri Ramchandra” in the name of its medical institution. This case sheds light on the complex intersection of religious names, trademark law, and the potential for confusion in the education sector.

Background of the dispute

SREHT, the registered proprietor of several trademarks incorporating “Sri Ramachandra,” has been using the mark in connection with medical education and healthcare services since 1985. The trust operates several educational institutions under this name and holds multiple trademark registrations covering various aspects of medical education, research, and services. These marks have been continuously used for decades, with substantial evidence of their prominence, including newspaper advertisements, academic achievements, and awards.

However, in November 2024, SREHT discovered that BAVPS had begun using the name “Shri Ramchandra Institute of Medical Sciences” for its medical college. This prompted SREHT to file a suit for trademark infringement and passing off. The trust argued that the defendant’s use of the mark was likely to cause confusion among the public, especially since both institutions operate in the same field of medical education.

The Defendant’s argument

BAVPS countered by asserting that the term “Sri Ramachandra” is a name associated with a deity, which is publici juris, and cannot be exclusively claimed by any individual or institution. The defendant pointed to several other institutions using similar names, some of which were dormant, as evidence that the mark was in the public domain.

Further, BAVPS relied on a lease deed from the year 2018, which outlined the establishment of a medical college on 25 acres of leased land. According to the deed, it was mutually agreed that the college would be named “Shri Ramchandra Institute of Medical Sciences.” BAVPS also provided documents showing that it had received necessary approvals, including a Letter of Permission from the Medical Assessment & Rating Board (MARB) in 2024, permitting the admission of medical students.

The Court’s findings

The Court’s examination focused on several key issues: prior use, acquired distinctiveness, and the likelihood of confusion between the marks. SREHT presented a compelling case of prior use, having held registered trademarks for “Sri Ramachandra” and its variants since 2011, long before BAVPS began using the mark. The evidence indicated that the trust’s marks had been continuously used in connection with educational services, and it had built significant goodwill in the name over the years.

BAVPS, on the other hand, failed to demonstrate that “Sri Ramachandra” was widely used by third parties, which could have potentially justified the claim that the name was in the public domain. The Court found that the defendant’s use of the mark “Shri Ramchandra” was likely to cause confusion among the relevant public, particularly since both marks were associated with medical education services.

In addition, the Court addressed the argument that “Sri Ramachandra” is a name of a deity. While the Court acknowledged that names of deities are not inherently subject to trademark protection, it ruled that SREHT had established a prima facie case of acquired distinctiveness. The trust had demonstrated that its use of the mark was not only long-standing but also had come to represent the institution’s educational services in the medical field.

Likelihood of Confusion and Balance of Convenience

One of the significant findings was the degree of similarity between the plaintiff’s mark, “Sri Ramachandra Medical College and Research Institute,” and the defendant’s mark, “Shri Ramchandra Institute of Medical Sciences.” The Court observed that despite BAVPS’s full institutional name being more extensive, the dominant elements—”Shri Ramchandra” and “Institute of Medical Sciences”—were likely to be used in everyday reference. This raised the likelihood of confusion, particularly in the context of both institutions offering identical services.

The Court also ruled that the balance of convenience favoured SREHT. It noted that the defendant’s medical college was still under construction, and the approval process was recent. Allowing BAVPS to continue using the disputed mark could potentially lead to an irreversible situation, further complicating matters for SREHT.

Interim Relief Granted

In light of the findings, the Court granted an interim injunction restraining BAVPS from using “Shri Ramchandra” as part of its medical college name. The order, however, would only take effect 15 days after the defendant’s receipt of the Court’s decision, giving BAVPS time to inform the relevant authorities and make necessary changes.

The Court emphasized that BAVPS could still continue operating its medical college under different names, such as “Dr. Babasaheb Ambedkar Vaidyakiya Pratishthan” or “R K Damani Medical College,” provided they were not deceptively similar to “Sri Ramachandra.”

Comment

This case underscores the importance of protecting long-standing trademarks in the education sector, even when the mark includes religious or commonly used names. The Court’s decision reaffirms that acquired distinctiveness and prior use can outweigh generic associations, especially when there is a risk of confusion.