Heart-Shaped Deception: Delhi High Court Cracks Down on Copycat “Little Hearts” Biscuits

Sonaliya
Legal Intern

07-Feb-2026

In a significant reaffirmation of trademark and trade dress protection in India, the Delhi High Court recently restrained the manufacture and sale of infringing “Little Hearts” biscuits, granting interim relief in favor of Britannia Industries Limited. The case underscores how Indian courts continue to take a strict view against dishonest adoption, particularly where iconic product shapes and well-known brands are concerned.

Britannia Industries Limited, one of India’s oldest and most trusted food companies, has been in continuous operation since 1918. The company adopted the trademark “Little Hearts” in 1988 and launched its now-iconic sugar-coated, heart-shaped biscuits in 1993. Over the decades, Little Hearts has evolved into a flagship brand, enjoying extensive goodwill, consumer recognition and nationwide distribution.

Britannia is the registered proprietor of the “Little Hearts” word mark, with user claims dating back to 1993. In addition, the company holds registrations for the three-dimensional shape of the biscuit, along with multiple registrations covering associated packaging, trade dress and variants of the mark.

The dispute arose when Britannia discovered that biscuits titled “Little Hearts Biscuits” were being offered for sale on Amazon by Shri Swastik Organics and other associated defendants. Upon purchasing the impugned product, Britannia found that not only was the identical mark being used, but the defendants had also replicated the distinctive heart-shaped biscuit. A side-by-side comparison of the rival marks and product shapes left little room for doubt. The Court held that the impugned mark and the three-dimensional biscuit shape were identical to Britannia’s registered trademark and shape mark.

A particularly damaging factor was the defendants’ product listing on Amazon, where the biscuits were expressly described as “Britannia Little Hearts” and displayed using copyrighted images belonging to Britannia. The Court treated this as a clear admission of dishonest intent and observed that the adoption was plainly mala fide, aimed at exploiting Britannia’s reputation and consumer trust.

The Court categorized the matter as a case of “triple identity. Given Britannia’s status as the prior adopter, prior user and registered proprietor, the likelihood of confusion in the mind of an average consumer with imperfect recollection was found to be inevitable.

In view of the strong prima facie case, the Delhi High Court restrained the defendants from manufacturing, selling, advertising or dealing in goods bearing the impugned mark or shape or any deceptively similar variant. The defendants were also prohibited from using Britannia’s copyrighted images. Importantly, Amazon was directed to delist and take down all infringing products, reiterating the responsibility of e-commerce platforms in addressing clear cases of intellectual property infringement.

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