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Lifestyle Equities C.V. & Anr. v. Amazon Technologies Inc.,
2025 INSC 1190 | Supreme Court of India | Bench: J.B. Pardiwala, J. | Decided on 07 October 2025
Headnote
The Supreme Court clarified that an unconditional stay on execution of a money decree is permissible only in exceptional circumstances, reaffirming that while Order XLI Rules 1(3) and 5(3) CPC are directory, they safeguard the balance between the rights of decree-holders and appellants. The case marks an important intersection of intellectual property enforcement, procedural fairness, and commercial justice.
Brief Facts
- The plaintiffs, Lifestyle Equities C.V. and its licensee, own the global trademark “Beverly Hills Polo Club (BHPC)”.
- They sued Amazon Technologies Inc. in the Delhi High Court alleging trademark and copyright infringement, claiming that Amazon’s platform allowed sale of products bearing deceptively similar logos.
- The defendant failed to appear despite notice and was proceeded ex parte in 2022.
- The Single Judge, in February 2025, passed an ex parte decree awarding:
- USD 38.78 million (~₹336.02 crore) in damages,
- ₹3.23 crore in costs, and
- A permanent injunction restraining use of the infringing mark.
- Amazon appealed before the Division Bench, which stayed execution of the decree unconditionally, subject only to an undertaking to comply if the appeal failed.
- The plaintiffs challenged this before the Supreme Court, arguing that the High Court violated Order XLI Rules 1(3) & 5(3) CPC, which require deposit or security for a stay of money decrees.
Statutes and Law Involved
Code of Civil Procedure, 1908
- Order XLI Rule 1(3) – Deposit or security for appeal against money decree.
- Order XLI Rule 5(1)–(5) – Conditions and discretion for stay of execution.
Arbitration and Conciliation Act, 1996 – Section 36(3) analogy drawn for stay of arbitral awards.
Trademark Act, 1999 – Protection of registered marks and injunction against infringement.
Legal Principles Culled Out
- Deposit or Security under Order XLI Rule 1(3) CPC is Directory, Not Mandatory– The provision ensures prudence, not rigidity. Its breach doesn’t invalidate an appeal but impacts entitlement to stay.
- Unconditional Stay Permissible Only in Exceptional Cases– Courts retain discretion to grant stay without deposit/security where grave procedural irregularities or injustice are evident.
- Balance Between Decree-holder’s Rights and Appellant’s Equity– Execution of money decrees should ordinarily not be stayed, since monetary restitution remains possible upon reversal.
- Judicial Discretion Must Be Reasoned and Not Arbitrary– Any stay must rest on a finding of “sufficient cause” — with cogent reasoning reflecting legislative intent.
- Arbitration Analogy (Section 36(3) Proviso)– Just as unconditional stay of an arbitral award is reserved for fraud or corruption, unconditional stay of decrees should be equally restrained.
The Verdict
- The Supreme Court upheld the Delhi High Court’s discretion in granting stay, emphasizing that such discretion is not mechanical but judicial.
- It, however, cautioned that unconditional stay must remain an exception, not a norm, and directed that appellate courts exercise this power only when prima facie injustice or serious irregularity is shown.
Impact Analysis
On Civil Procedure:
- The judgment refines procedural jurisprudence under Order XLI CPC, harmonizing legislative history with equitable discretion.
- It protects appellants from procedural hardship in cases of ex parte decrees while ensuring that decree-holders’ rights are not lightly frustrated.
On Business and Arbitration:
- For corporates, especially in cross-border IP and commercial disputes, the ruling signals that monetary decrees may not translate into immediate enforcement where procedural fairness is questionable.
- It also reinforces that commercial agreements and business liabilities cannot bypass procedural justice — echoing fairness even in high-stake IP battles.
Judgments Relied Upon
- Sihor Nagar Palika Bureau v. Bhabhlubhai Virabhai & Co. (2005) 4 SCC 1
- Malwa Strips Pvt. Ltd. v. Jyoti Ltd. (2009) 2 SCC 426
- Kayamuddin Shamsuddin Khan v. State Bank of India (1998) 8 SCC 676
- Sunil Poddar v. Union Bank of India (2008) 2 SCC 326
- Atma Ram Properties (P) Ltd. v. Federal Motors (P) Ltd. (2005) 1 SCC 705
- LT Foods Ltd. v. Saraswati Trading Co. 2022 SCC OnLine Del 3694
- Padma Sundara Rao v. State of Tamil Nadu (2002) 3 SCC 533
Author
Abhijit Banerjee, Advocate-on-Record & Arguing Counsel, Supreme Court of India
Jurisprudence-Interplay between procedural equity and commercial justice under civil and arbitral framework.
Disclaimer: This summary is intended solely for academic and informational purposes and should not be construed as a legal interpretation of the judgment.
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