In a significant win for global water heater manufacturer A.O. Smith, the Delhi High Court on December 24, 2025, restrained Star Smith Export Pvt. Ltd. from using the marks Star Smith and the domain starsmith.in, holding them deceptively similar to the US company’s long-established brand identity.
The order came from Justice Tejas Karia while deciding an injunction plea filed under Order 39 Rules 1 and 2 of the Code of Civil Procedure. The court noted that allowing the defendants to continue using the trade name would cause confusion for consumers in the same product market.
Background of the Case
A.O. Smith, founded in 1874 and operating in India since 2006, approached the court in 2022 alleging that Star Smith’s use of similar names, marks, and domains was an attempt to ride on its market goodwill. The plaintiffs argued that “SMITH” formed the dominant and recognizable portion of their registered trademarks and had gained recognition both in India and globally.
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Star Smith, however, countered that the word “Smith” was a common name in trade and could not be monopolized by any single brand. They also contended that their products were visually distinguishable and did not mislead buyers.
Court Observations
Justice Karia rejected the defendants’ argument, noting that their own applications for trademark registration contradicted their claim that “Smith” was generic. The court emphasized that the adoption of the name in 2020 decades after A.O. Smith’s market presence appeared neither innocent nor coincidental.
“The mark ‘SMITH’ is the dominant part of the plaintiffs’ trademark. The defendants’ adoption of a deceptively similar trade name is likely to mislead customers,” the court noted.
Further, the judge held that the disputed domain starsmith.in could cause “initial interest confusion,” where a consumer is misdirected online before realizing the websites are unrelated.
Justice Karia remarked that even if a buyer later understands the difference, the damage of attracting traffic through misleading similarity still amounts to passing off. The court added:
“A party cannot approbate and reprobate. The defendants’ use of the impugned trade name and domain is infringing and cannot be permitted.”
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Court Decision
Concluding that A.O. Smith had established prior use, reputation, and the likelihood of confusion, the court issued a firm injunction against Star Smith. The defendants and their associates are now restrained from using:
- The trade name Star Smith Export Pvt. Ltd.
- The domain starsmith.in
- Any other name deceptively similar to A.O. Smith in connection with water purifiers, geysers, RO systems, or related products.
Justice Karia allowed the plaintiffs’ application and disposed of the matter, holding that permitting continued use would cause irreparable harm to the established brand identity of A.O. Smith.
Case Title:- A.O. Smith Corporation vs Star Smith Export Pvt. Ltd.
Case Number: CS(COMM) 532/2022
