Delhi High Court Declines To Cancel 'Patanjali Gonyle' Trademark On Plea By Holy Cow Foundation

A Single-Judge Bench of Justice Tejas Karia, in a judgment delivered on January 9, 2026, dismissed a trademark rectification plea filed by Holy Cow Foundation, which also sells a cow-urine-based cleaner product under thr same name, seeking removal of Patanjali's “Gonyle” mark over claims of deceptive similarity.

Observing that the competing marks were not confusingly similar, the court held, “In the present case, while there may be some phonetic similarity between 'GAUNYLE' and 'GONYLE', this Court cannot overlook the critical distinguishing feature of the Impugned Mark, namely, the prominent presence of the well-known House Mark, 'PATANJALI.'”

Holy Cow Foundation told the court that it had introduced “Gaunyle” in 2013 as an eco-friendly alternative to chemical floor cleaners and had obtained trademark registration for the mark in 2015. It claimed that Patanjali subsequently adopted the phonetically similar mark “Gonyle,” resulting in market confusion.

Patanjali, however, asserted that it had been using the “Gonyle” name since 2008 and had applied for trademark registration prior to Holy Cow Foundation. It also pointed out that its product is sold under the well-known “Patanjali” brand name, which clearly distinguishes it from other products in the market.

Upon examining the record, the Court found serious inconsistencies in the documents produced by Holy Cow Foundation to establish prior use of “Gaunyle.” It noted that the invoices relied upon by it to show use since 2013 appeared unreliable. In contrast, Patanjali's trademark application for “Gonyle” was filed earlier, strengthening its claim of priority.

Referring to the Supreme Court's ruling in Cadila Health Care Ltd. v. Cadila Pharmaceuticals Ltd., the Court reiterated that in assessing deceptive similarity, the overall impression of the mark must be considered. Applying this principle, it held that the prominence of the 'PATANJALI' house mark in the disputed mark significantly reduced the likelihood of confusion.

The court also noted that although goods covered by the two marks are broadly related to cleaning products, they are described differently in their respective trademark registrations, which also weighed against a finding of deceptive similarity.

Concluding that Holy Cow Foundation failed to prove prior use or deceptive similarity, the court dismissed its rectification plea and allowed the “Patanjali Gonyle Floor Cleaner” trademark to remain on the Trade Marks Register.

Case Title: Holy Cow Foundation v. Patanjali Gramodyog Nyas (Trust) And Ors.

Citation: 2026 LLBiz HC (DEL) 31

Case Number: C.O. (COMM.IPD-TM) 85/2021

For Petitioner: Advocates Subhashree Sil, Kuber Mahajan & Abhay Aren

For Respondent: Advocates Junaid Alam, Nishant Mahtta, S. Nitin & Nitish Singh