Dhariwal Industries Ltd. & Anr vs M/S M.S.S. Food Products

The Supreme Court upheld the trial court's decision to grant an interim injunction under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908, in a passing off action concerning the trademarks 'Malikchand' and 'Manikchand'. The Court found that the plaintiff established a prima facie case, with the balance of convenience favoring the plaintiff due to potential irreparable harm and loss of reputation from the defendants' use of a deceptively similar mark. The High Court's dismissal of the defendants' appeal was affirmed, emphasizing the need for expeditious trial resolution.