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Ajanta LLP vs Casio Keisanki Kabushiki Kaisha d/b/a Casio Computer Co. Ltd.

Civil Appeal · 2022 INSC 151Decided 4 Feb 2022
Civil Appeal No. 1052 of 2022
L. Nageswara Rao · B.R. Gavai

Background

Casio sued Ajanta LLP in the Delhi High Court, alleging that Ajanta's "ORPAT FX-991ES PLUS" calculator copied the registered design and trademark of Casio's "CASIO FX-991ES PLUS" calculator. After mediation, the parties signed a Settlement Agreement in 2019 under which Ajanta agreed not to use the design or the marks "FX-991ES PLUS"/"FX"/"991," and the High Court passed a consent decree in these terms. Ajanta later sought to modify the decree, claiming a typographical/settlement error, arguing the agreement was only meant to cover "FX-991ES PLUS" as a whole, not the standalone generic term "FX," and that it should be free to keep using "FX." The High Court dismissed this modification application, and Ajanta appealed.

Decision Breakdown

The Supreme Court dismissed the appeal and upheld the consent decree as originally worded. Reviewing months of email correspondence between the parties' lawyers, the Court found no genuine misunderstanding: the final settlement language restricting use of "FX" and "991" separately was communicated clearly and went unopposed by Ajanta before signing. The Court reaffirmed that a consent decree, once validly entered, creates an "estoppel by judgment" and can only be reopened if it is shown to be vitiated by fraud, misrepresentation, or a genuine, obvious mistake, not merely because one party later regrets specific terms it did not object to at the time.

Lesson Learnt

Once you sign a settlement agreement and a court passes a decree based on it, you generally cannot get it reworded later merely by claiming you misunderstood a term. Courts will hold parties, especially those represented by lawyers through extended negotiations, to the plain terms they agreed to.

Official source (sci.gov.in)View Judgment (PDF)

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