Trademark Passing Off and Film Titles: Bombay High Court Rejects Injunction Against Queen Full Power

sketch of the Bombay High Court
Case
PHANTOM STUDIOS INDIA PRIVATE LIMITED v. JIOSTAR INDIA PRIVATE LIMITED (Bombay High Court, 14-10-2026)
Law
Code of Civil Procedure, Indian Contract Act, Copyright Act.

Highlights of the Judgment:

  • Application of the classical trinity test for establishing passing off regarding unregistered film titles.
  • Judicial interpretation of secondary meaning and distinctiveness thresholds for generic terms like queen.
  • Legal analysis of spiritual sequels and derivative works under intellectual property and contract law.
  • Evaluation of the group of companies doctrine for binding non-signatories to commercial agreements.
  • Scrutiny of the admissibility of media reports and social media posts to prove consumer confusion.
  • Assessment of irreparable injury, balance of convenience, and documentary disclosure rules under the Civil Procedure Code.