The Delhi High Court has granted an ex parte ad interim injunction in favour of LexisNexis, restraining Parth Law House and other unidentified parties from publishing, distributing or selling counterfeit copies of some of its most authoritative legal textbooks, observing that the defendants’ actions not only tarnish the publisher’s reputation but also adversely impact students and professionals.
The order was passed by Justice Jyoti Singh in a commercial suit filed by LexisNexis, a division of RELX India Pvt. Ltd., alleging large-scale infringement of its trademarks and copyrights in three leading legal commentaries.
Exemption from Pre-Institution Mediation Granted
At the outset, the Court allowed the plaintiff’s plea seeking exemption from mandatory pre-institution mediation under Section 12A of the Commercial Courts Act, 2015, noting the urgency of the matter. The Court relied on the Supreme Court’s judgment in Yamini Manohar v. T.K.D. Keerthi and a Division Bench ruling of the Delhi High Court in Chandra Kishore Chaurasia v. RA Perfumery Works Private Ltd. to hold that urgent relief justified such exemption.
The Court also condoned a delay of 71 days in re-filing the plaint and permitted the plaintiff to place on record original hard copies of the alleged counterfeit books.
Allegations of Counterfeiting Popular Legal Textbooks
LexisNexis informed the Court that it publishes several reputed legal titles in India and globally, including digital platforms such as Lexis+, Lexis Advance and Lexis Practical Guidance. The present dispute concerns three widely used textbooks:
- Pollock & Mulla – The Indian Contract & Specific Relief Acts (17th Edition)
- N.S. Bindra – Interpretation of Statutes (13th Edition)
- Mulla – The Code of Civil Procedure (20th Edition)
According to the plaint, these works have acquired immense goodwill through sustained editorial efforts, quality control, marketing and distribution. The plaintiff asserted that the titles and authors’ names have become uniquely associated with its publishing imprint.
It was alleged that the defendants—retailers, printers and distributors—were engaged in printing and selling exact replicas of these textbooks under the registered “LexisNexis” trademark. The plaintiff further claimed that counterfeit copies were being sold even within the premises of a trial court in Delhi. In addition to the named defendant, a “John Doe” defendant was impleaded to cover other unknown infringers.
Inferior Quality and Fake Holograms
Senior counsel appearing for the plaintiff argued that the counterfeit books were created by scanning original editions and reproducing them in inferior quality. The Court was shown a comparative analysis between genuine and counterfeit copies.
It was submitted that while original LexisNexis textbooks carry secure holograms with QR codes that authenticate the ISBN through the company’s website, the counterfeit books bore holograms that could be wiped out by rubbing and QR codes that led to invalid applications. Differences in printing quality, binding, cover design and scanned text were also highlighted.
The plaintiff contended that such counterfeiting not only infringed its statutory trademark and copyright protections but also misled students and legal professionals, who may unknowingly purchase substandard editions.
Court Finds Prima Facie Case of Infringement
After examining the pleadings and documents, Justice Jyoti Singh observed that a prima facie case had been established for the grant of interim relief.
The Court held that the balance of convenience lay in favour of the plaintiff and that irreparable harm would ensue if an injunction were not granted. In a significant observation, the Court noted that the defendants were manufacturing and selling counterfeit textbooks of inferior quality, equipped with holograms that could be easily erased.
The Court further remarked that LexisNexis had built a formidable reputation and goodwill in the legal publishing market and that the sale of counterfeit books harmed not only the publisher but also the public interest—particularly students and professionals relying on authentic legal texts.
Injunction and Next Steps
Accordingly, the Court restrained the defendants, their partners, agents and affiliates from publishing, selling, advertising or dealing in any books that are substantial reproductions of the plaintiff’s textbooks, amounting to copyright infringement and reputational tarnishment.
Summons have been issued to the defendants, who have been directed to file written statements within 30 days of receipt. The matter is listed before the Joint Registrar for further proceedings, including admission and denial of documents, and is scheduled for further hearing on February 26, 2026.
Case Details
Case Title: LEXISNEXIS A DIVISION OF RELX INDIA PVT LTD Versus PARTH LAW HOUSE & ANR.
Citation: JURISHOUR-92-HC-2026(Del)
Case No.: CS(COMM) 156/2026
Date: 17/02/2026
Counsel For Petitioner: J. Sai Deepak, Senior Advocate
