Published on: 01st February 2026
Authored by: Mansi Gohil
Parul Institute of Law
Court: Supreme Court of India
Bench: L Nageswara Rao, BR Gavai, BV Nagarathna JJ
Introduction
The Supreme Court case, Renaissance Hotel Holdings Inc v Vijaya Sai, is a really important one for trade mark stuff in India. It’s all about how to read Sections 29(2), 29(3) and 29(5) of the Trade Marks Act 1999. Basically, the court had to figure out if the hotel SAI RENAISSANCE was too close to the registered trade mark RENAISSANCE which belongs to the big hotel chain, Renaissance Hotel Holdings Inc. The first court said it was a problem, but the Karnataka High Court disagreed. In the end, the Supreme Court said the first court was right – the names sounded and looked too much alike, so it was trade mark violation.
This decision matters because it makes it clear that if you copy a registered trade mark pretty closely – especially if it’s part of a business name in the same business – it’s assumed you’re violating the trade mark. It also says that just adding a word at the beginning doesn’t make it okay, and you can’t just say you picked the name for some other reason to get out of trouble.
Background
Renaissance Hotel Holdings Inc is from the US and a big deal in the hotel world. They said they started using the trade mark RENAISSANCE way back in 1981, and in India since 1990, for hotels and restaurants. They’ve got the trade mark registered here for things like printed stuff and hotel services.
Back in 2008, they came across online material showing that a hotel in india was using the name SAI RENAISSANCE. Renaissance Hotel Holdings Inc said that their signs, cards, and ads used the word Renaissance and even looked a lot like their own branding. They thought people would think SAI RENAISSANCE was part of their company. so, they sent a warning letter telling them to stop. When that didn’t work, they sued to stop them for good, get money for the damage, and make them hand over anything that used their trade mark.
Submissions of the Defendants
The other side said they weren’t doing anything wrong and weren’t trying to make money off Renaissance Hotel Holdings Inc’s name. They said Renaissance is a normal word that means rebirth, and it meant spiritual rebirth to them. The SAI part was because they were into some gurus. One of the owners even had Sai as his middle name.
They also said their hotels were for people visiting holy places, served only vegetarian food, and weren’t the same kind of customers as fancy hotels like Renaissance Hotel Holdings Inc’s. They thought rich hotel customers wouldn’t think of their hotels as the same thing.
Plus, they claimed Renaissance Hotel Holdings Inc waited too long to complain, since they’d been around since 2001.
Lastly, they said they were using the name honestly and didn’t want to trick anyone into thinking they were Renaissance Hotel Holdings Inc.
Decision of the Trial Court
The first court agreed with Renaissance Hotel Holdings Inc. They pointed out:
- Renaissance Hotel Holdings Inc had the trade mark for RENAISSANCE registered in India.
- The hotel was using the same word in their name, which is a problem under the law. • Both companies were in the same business – hotels.
- Because the names were so similar, people would probably get confused.
So, the court told the hotel to stop using SAI RENAISSANCE or anything close to RENAISSANCE.
Findings of the High Court
But the Karnataka High Court didn’t see it that way. They said:
- Renaissance Hotel Holdings Inc didn’t prove they were that well-known in India.
- The word Renaissance is pretty common.
- The hotel’s story about the spiritual meaning of Sai Renaissance made it sound like they weren’t trying to be dishonest.
- The hotels had different customers fancy hotel people versus people visiting holy sites.
The High Court said that Renaissance Hotel Holdings Inc didn’t prove the hotel was trying to take advantage of their name. So, they threw out the first court’s decision.
Issues Considered by the Supreme Court
The Supreme Court had to decide :
- Did the Appeal Court use the wrong part of the law?
- Was the hotel violating the trade mark by using SAI RENAISSANCE? • Did adding SAI make enough of a difference?
- Did the hotel pick the name honestly?
- Did Renaissance Hotel Holdings Inc have to prove people would be confused? Reasoning of the Supreme Court
- Wrong Section Applied:
The Supreme Court said the High Court applied the wrong legal provision. That section is for cases involving different goods or services. Here, both parties were in the hotel business, so other sections applied.
- Similarity Amounts to Infringement:
The Court said using an identical or nearly identical registered trade mark does not require proof of actual confusion. If the names are close, it’s automatically infringement. Since RENAISSANCE was fully inside SAI RENAISSANCE, the rule applied.
- Adding ‘SAI’ Is Insufficient:
The Court held that adding a prefix or suffix does not cure infringement if the dominant part remains the same.
- Visual and Phonetic Similarity:
The Court noted that Renaissance and Sai Renaissance look and sound similar. Ordinary customers could easily think the two were connected.
- Use in Business Name Violates Section 29(5):
The law clearly prohibits using a registered trade mark as part of a business name in the same business category. The defendants violated this.
- Lack of Honest Adoption:
The Court rejected the spiritual explanation and observed that the website and signage resembled the plaintiff’s branding.
- Delay Not a Defence:
Even if there was some delay in filing the suit, infringement continues to be infringement.
Final Decision
The Supreme Court held that the High Court was wrong and restored the Trial Court’s orders. The defendants:
- Could not use the name Sai Renaissance anymore.
- Could not use Renaissance for hotel-related services.
- Had to stop using any trade mark that violated RENAISSANCE.
The Court concluded that the defendants were clearly infringing the trade mark. Importance of the Judgment
This judgment clarifies:
- How Sections 29(2), 29(3), and 29(5) of the Trade Marks Act should be read. • That adding an extra word does not avoid infringement.
- That hotel trade marks enjoy strong protection.
- That confusion is presumed when names are highly similar.
- That using a registered mark in your business name is infringement. • That delay in filing a suit does not excuse ongoing infringement.
Conclusion:
The Supreme Court’s decision reinforces that trade mark owners enjoy strong statutory protection, and businesses cannot adopt names that are deceptively similar to established marks. Visual and phonetic similarity, along with the likelihood of confusion for a reasonable customer, remains the core test for infringement.
Citation:
- Renaissance Hotel Holdings Inc v Vijaya Sai (2022) 65 Livelaw (SC) • Trademark Act 1999, sec.29(2),29(3),29(5).
