Delhi High Court Issues Interim Injunction to Volvo, Halting Fake Bus Manufacturers in Trademark Dispute

Protecting Brands: Delhi High Court Halts Fake Volvo Bus Makers in Landmark Trademark Ruling

The Delhi High Court, in a landmark case to protect the identity of a brand and avoid consumer deception, temporarily restrained certain Indian bus manufacturers and operators from using the ”CROSS COUNTRY” name.

In a decision made on May 30, 2025, in the case Aktiebolaget Volvo & Ors v. Shri Ganesh Motor Body Repairs & Ors (CS(COMM) 601/2025), Justice Amit Bansal issued a temporary order stopping these companies from using the important Volvo trademark and the unique design of the buses. This decision reinforces the strength of registered Indian trademarks as well as provides a message of no trespassing on intellectual property.

The Heart of the Matter: A Design Deception

It was prompted by a case filed in the Delhi High Court by Sweden’s Volvo, one of the world’s largest manufacturers of heavy trucks and buses. While the trademark “VOLVO” is owned by the parent companies of the Volvo group dating back to 1915, Volvo India Pvt Ltd was established only in 1996.

The iconic name and their “grille-slash mark” logo (a diagonal stripe cutting across the grille) are famous the world over, with nearly the same brand recognition that they enjoy in North America, having developed a stellar reputation even in India.

Volvo claimed that some companies in India produced and operated buses that resembled “very closely” genuine Volvo buses, even using the “VOLVO” name as well as the characteristic Volvo grille/slash design.

Picture that you approach a bus at a bus stand and you see a bus that is identical to a Volvo, even carrying the logo, but it instead represents a different company. And that is exactly what was taking place.

These fake buses were all intended to fool the customers into thinking they were riding in a real Volvo and thus gain an advantage from Volvo’s established reputation for quality and safety. In fact, one defendant manufacturer even acknowledged that it manufactured and sold more than 100 such buses with the offending logos.

Understanding Trademark Infringement: A Legal Battle

This is a case of trademark infringement. A trademark is essentially a business’s or service’s source identifier. The mark in question could be a word, a logo, a shape, or even a color combination.

Its primary function is to help consumers’ recognition and differentiation of a particular product or service and its source. That is, the brand name “swoosh” logo immediately brings to mind Nike tennis shoes, or the word “Coca-Cola” evokes memories of a particular brand of soft drink. The illegal use of a confusingly similar badge and its ability to create consumer confusion with it is called trademark infringement.

The Trademarks Act, 1999 is the principal statute dealing with trademarks in India. Consider a few of the sections that are very pertinent to this Volvo case:

What is a Trademark? (Section 2(1)(zb) of The Trademarks Act, 1999)

You might ask, “What is a ‘trademark’?” before we discuss infringement.

• Deceptively similar simply means it’s so close in look or sound to the original that it’s sure to mislead consumers. Now imagine that there are two competing private bus companies with names that could easily be imagined as “Volbo” and “Volov,” both introducing the same new branding plan. This would be a straightforward imitation designed to deceive the average person into thinking they are genuinely using the authentic product from Volvo.
  
• 1. As discussed above, defendants were indeed using these marks in commerce, producing school buses and providing bus transportation services. This established that their use was “in commerce,” which is an essential element of trademark infringement. The Court determined that the infringement was “willful and misleading,” leading to the production of “sham/replica/counterfeit/lookalike products.”
  
• a/counterfeit/lookalike products.” This is no ordinary trademark infringement. It is an especially pernicious effort to confuse consumers and obfuscate from them that they were purchasing or engaging The Court determined that the infringement was “willful and misleading,” resulting in the production of “sham/replica/counterfeit/lookalike products.” duction of “sham/replica/counterfeit/lookalike products.” one party attempts to obtain an unjust benefit from the reputation established by another.
  

The Court’s Decision and its Impact

Using the very strict evidence standard set by Volvo, Judge Amit Amit Bansal decided that Volvo was right to get temporary protection and had proven a strong initial case that there was a good chance of serious harm to their rights. 

That’s why we were ecstatic when the court granted our preliminary injunction, halting implementation of the terrible rule. Accordingly, the enjoined defendant companies, their officers, agents, and employees, and each of them, are hereby ORDERED and PERMANENTLY ENJOINED from (i) manufacturing, marketing, selling, or advertising, or otherwise engaging in any business under the “VOLVO” mark, including its distinctive grille-slash trade dress. The next hearing in this costly and glacial beauty contest isn’t even scheduled until October 9, 2025.

Regardless of what the Supreme Court ultimately decides if this returns, this ruling is already an historic victory for Indian IPR. Law Review article from way back in late 2016 Nevertheless, it still does a fantastic job of articulating the case that the companies, big or small, that put in the time and energy to build a brand and reputation ought to be protected from cutthroat competition from those who would seek to free ride on their hard-won success through imitation.

To brand owners, it’s leading to more transparency and a higher level of consumer confidence that the products and services they’re choosing are indeed from the brands they seek to do business with. The Delhi High Court’s iron-willed stance serves as a well-earned cautionary tale that bad faith copying or market confusion has no place in the marketplace, safeguarding vibrant competition for innovators and authentic choice for consumers.