The DHC, in the case of Vikrant Chemico Industries Pvt. Ltd. v. Shri Gopal Engineering and Chemical Works Pvt. Ltd. & Ors.,^[1] by way of an Order dated August 20, 2025, has clarified that its territorial jurisdiction cannot be invoked by the plaintiff solely on the basis of the defendant’s goods being listed on a passive website accessible in Delhi. It was held that the mere availability of a website where no actual commercial transactions or sales occur, would be insufficient to constitute specific targeting of customers in Delhi, and would, therefore, not be adequate to invoke the territorial jurisdiction of the DHC.

The DHC further noted that the plaintiff failed to produce concrete evidence of any commercial activity or sales in Delhi through the defendant’s website or otherwise. It also rejected claims relying solely on trademark registration or assignment deed being executed in Delhi as a basis for invoking its jurisdiction. Consequently, the suit was returned to the plaintiff for want of territorial jurisdiction.

[1] Vikrant Chemico Industries Pvt. Ltd. v. Sri Gopal Engineering and Chemical Works & Ors., 2025 SCC OnLine Del      5562.