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Delhi High Court Restrains Patanjali Ads Calling Other Chyawanprash “Dhoka”

The Delhi High Court found a prima facie case of generic disparagement in a Patanjali ad, ordered it disabled within 72 hours of receipt, and left the underlying suit unresolved.
From TheFinanceBase Team3 min to read
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The Delhi High Court on 6 November 2025 temporarily restrained Patanjali Ayurved and Patanjali Foods from airing or distributing an advertisement that described other Chyawanprash as “dhoka” (deception). The Court found a prima facie case of disparagement even though the ad did not name Dabur directly: it said a message attacking Chyawanprash as a whole could harm a competitor whose product belonged to that category. The order is interim, not a final ruling in Dabur’s suit.

What the Delhi High Court ordered

In Dabur India Limited’s suit, CS(COMM) 1182/2025, Justice Tejas Karia ordered the defendants and entities acting on their behalf to stop issuing, broadcasting or disseminating the challenged advertisement and other advertisements that disparage Chyawanprash generally. The restraint covered ads that called Chyawanprash “dhoka” or “deception,” claimed it had no medical value, attribute or benefit, or otherwise denigrated the category, including Dabur’s product.

The defendants were also directed to take down, block or disable the challenged advertisement across electronic media, television, digital media, internet platforms, print and social accounts within 72 hours of receiving the order. The restraint was to operate until the next hearing; it did not finally decide the suit.

Why an ad that did not name Dabur was challenged

Dabur alleged denigration, disparagement, defamation and unfair competition, including disparagement of both its product and Chyawanprash as a category. In the ad sequence reproduced in the order, a mother says “Chalo … Dhoka Khao!” and the advertisement says that most consumers are being deceived in the name of Chyawanprash.

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The Court considered the ad’s overall message and context, rather than treating the absence of Dabur’s brand name as decisive. It reasoned that calling all other Chyawanprash “dhoka” conveyed that their manufacturers were deceiving consumers, and that a generic attack on the category could harm a competing product within it. The Court’s conclusion was at the prima facie stage, not a final finding after trial.

How the order distinguishes comparison from disparagement

The Court said comparative advertising is permissible in principle: an advertiser may emphasize a particular quality or feature of its product. But a comparison must not disparage a competitor or mislead the target consumer. The order frames the assessment around how the advertisement’s message would be understood by its intended audience.

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The distinction is between promoting a product’s own claimed strengths and denigrating competitors as a class. As the Court put it, “Calling all other Chyawanprash as ‘dhoka’ or deception amounts to commercial disparagement.” It also said that although advertisers may exaggerate or embellish their own goods’ virtues, they may not “denigrate or disparage the goods of the others as a class in its entirety.”

How the case reached the November 2025 order

Date Proceeding What happened
3 July 2025 Earlier suit, CS(COMM) 1195/2024 The Delhi High Court granted interim relief concerning specified Patanjali Chyawanprash advertising. Delhi High Court order, as cited in the later order.
23 September 2025 Appeal from the July order As recounted in the November order, a Division Bench upheld a restriction on a particular claim invoking Ayurvedic tradition and allowed comparison with “ordinary Chyawanprash” only on condition that it not deride or directly or indirectly refer to Dabur’s product.
6 November 2025 New suit, CS(COMM) 1182/2025 Justice Tejas Karia granted ad-interim relief, ordered removal or disabling of the challenged ad within 72 hours after receipt, and listed the case for 26 February 2026. Delhi High Court order.
16 July 2026 Later docket entry Justice Anup Jairam Bhambhani recorded that no parties appeared because of a Delhi High Court Bar Association abstention call. The matter was re-notified before the Joint Registrar for 30 September 2026, with court listing thereafter. The outcome of that September listing is not established by this docket entry. Delhi High Court order.
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What the decision does—and does not—settle

The November order gives Dabur interim protection while the suit proceeds. Dabur’s suit seeks broader remedies, including permanent and mandatory injunctions and damages, but the Court did not finally decide those claims in the 6 November order. The later docket entry shows the matter continued into 2026; it does not establish the result of the 30 September 2026 listing or a final disposition.

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The order reproduces the advertisement’s claim that Patanjali Special Chyawanprash contains “51” medicinal herbs. That is an advertising claim recorded in the order, not a product fact independently verified or adopted by the Court.

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