The Delhi High Court has dismissed a trademark rectification petition filed by Holy Cow Foundation, seeking cancellation of Patanjali’s registered mark “Patanjali Gonyle Floor Cleaner.” The court held that the petitioner failed to prove prior use and found no real likelihood of consumer confusion.
The decision was delivered by Justice Tejas Karia of the Delhi High Court on January 9, 2026.
Background of the Case
The dispute arose from a rectification petition filed by Holy Cow Foundation, a non-governmental organisation working with gaushalas and promoting cow-based products.
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The Foundation claimed it developed and marketed a cow-urine-based floor cleaner under the trademark “Gaunyle” from 2013 and secured trademark registration in Class 05. According to the petitioner, Patanjali’s use of the mark “Patanjali Gonyle Floor Cleaner” was phonetically identical and intended to ride on its goodwill.
The respondents, led by Patanjali Gramodyog Nyas, countered the claim, asserting use of the mark “Gonyle” since 2008 and highlighting their earlier trademark application and registration.
The petitioner argued that both products were cow-urine-based floor cleaners sold through similar trade channels, creating a real risk of confusion. It also relied on media reports allegedly mixing up “Gaunyle” and “Gonyle” as evidence of actual confusion.
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On the other hand, the respondents maintained that:
- They were prior users and registered proprietors.
- Their mark prominently carried the well-known house mark “Patanjali,” which clearly distinguished the source.
- The petitioner’s documents claiming earlier use were unreliable and inconsistent.
Court’s Observations
The court emphasised that prior use must be proved with credible evidence, not merely claimed. Examining the invoices filed by the petitioner, the bench found serious inconsistencies in dates and numbering.
“The burden of proving prior adoption lies on the party asserting it, and that burden has not been discharged,” the court observed.
On the issue of similarity, the court accepted that “Gaunyle” and “Gonyle” share phonetic resemblance but clarified that trademarks must be assessed as a whole.
The bench noted, “The prominent presence of the well-known house mark ‘Patanjali’ acts as a strong distinguishing feature, substantially reducing any likelihood of confusion.”
Justice Karia held that:
- The petitioner failed to establish continuous and genuine use prior to Patanjali.
- Patanjali’s trademark application preceded the petitioner’s filing.
- The overall impression of “Patanjali Gonyle Floor Cleaner” was distinct due to the strong brand identity of “Patanjali.”
The court also remarked that absence of a product mention in media reports could not be treated as proof of non-use.
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Court’s Final Decision
Concluding the matter, the Delhi High Court dismissed the rectification petition and upheld the trademark registration of “Patanjali Gonyle Floor Cleaner.”
“The impugned mark does not deceive the public nor cause confusion,” the court ruled, adding that there was no legal ground to remove the mark from the Trade Marks Register.
The petition was dismissed with no order as to costs.
Case Title: Holy Cow Foundation v. Patanjali Gramodyog Nyas & Ors.
Case No.: C.O. (COMM.IPD-TM) 85/2021
Case Type: Trademark Rectification Petition
Decision Date: January 9, 2026
