Trademark case law Atyati v. Cognizant - KLS Advisors

SUPPRESSION OF FACTS, IF “DEBATABLE,” NOT A VALID GROUND

FOR INTERIM INJUNCTION.

   (Atyati Technologies Vs. Cognizant Technology Solutions)

Background & Facts

Atyati Technologies adopted the mark “ATYATI” in 2008 and introduced a new honeycomb-style logo in 2019. In October 2023, it alleged that Cognizant’s 2022 logo was deceptively similar and issued a cease-and-desist notice. Acting on Atyati’s plea, a Bombay High Court single judge, in March 2024, passed an ex parte interim order restraining Cognizant from using the logo. However, in June 2024, the same judge vacated the order and permitted Cognizant to continue using the logo pending the case. On appeal, a Division Bench of the Bombay High Court, in August 2024, set aside this ruling and again restrained Cognizant. Finally, in September 2025, the Supreme Court intervened, set aside the Division Bench’s order, restored the single judge’s June 2024 decision, and allowed Cognizant to continue using its logo, while directing that Atyati’s injunction application be decided within six months.

Contentions in the present Appeal

Cognizant countered that Atyati had suppressed material facts, as its own cease-and-desist notice revealed the disputed logo was adopted only in March 2022. It contended that the Division Bench erred in overturning the single judge’s June 2024 order, which had lifted the restraint, and emphasized the severe business disruption caused by being barred from using its corporate logo in India.

Atyati Technologies argued that its honeycomb-style logo, adopted in 2019, was an original artistic work and that Cognizant’s 2022 logo was deceptively similar, amounting to infringement despite minor differences. It maintained that the Division Bench was right to restore the restraint since Cognizant’s claim of suppression was at best debatable.

Order

The Supreme Court held that the Division Bench erred in overturning the single judge’s order. It clarified that there was no bar on Cognizant from using its logo while the dispute is pending, and the Division Bench should not have reinstated the ex parte restraint merely because suppression was “debatable.”

Implication

The Supreme Court’s reasoning—that there is no absolute bar on Cognizant using its logo during pendency and that the Division Bench wrongly reinstated an ex parte restraint—implies that interim injunctions in IP disputes must be carefully balanced to avoid disproportionate hardship.