INTRODUCTION:

It is often said that “Necessity is the mother of invention”. However, in present times the reverse of it is true. In modern times the context of ‘Invention being the mother of necessity’ can be seen¹. In this present era of battle of brands, new products are produced every day.

Further, now a days markets are created for these products and are informed to public through advertisements. Producers advertise their products in numerous ways to effectively spread information to prospective customers.

Today, the business sector is fixated on building one brand's better claim over the other. Organizations have begun embracing an extremely slice edge way to leave their rivals far in the race to demonstrate their items as the best amongst the bunch. They put into practice various types of publicizing methods, for example, undercover ad or big name promotion to convey their items to get the consideration of its customers.

Trade rivalries and comparative advertising have been an old trend in the advertising scene and the customers have seen endless product wars on their TV sets. The idea of comparative advertising developed in the nineties. The nineties period saw the Pepsi-Coke war which was trailed by Complan-Horlicks tow of war and the most recent in the wicker bin is the Rin-Tide war and the Colgate- Pepsodent tussle. Each of these promotions trashed the contender's item to showcase the prevalence of their item in the business sector. The key to comparative advertising lies in delineation of the opponent goods in a careful yet decisive design. India does not have set up devoted statue overseeing the zone of Comparative Advertising. As of late, comparative advertising has turned into a multibillion dollar business and has tested courts with new, complex legitimate issues identified with the privileges of buyers, advertisers and their rivals.

Until as of late a few mainland European nations totally had banned any type of comparative advertising though, in the US, the utilization of comparative advertising has really been supported by the Federal Trade Commission ever since the 1970's. While in the past the European and American approach towards this sort of publicizing was particularly diverse, today rivalry powers concur in considering comparative advertising as a vital device in advancing rivalry, such that organizations and retailers are encouraged to utilize comparative advertisements. Moreover, within the European Union the UK has today a quite tranquil approach to comparative advertising. The basis is that comparative advertising, if reasonable and not deceiving, is guaranteed to build consumers' information about alternative brands, products and services and to absolutely influence rivalry among (domestic and cross-border) firms. An analogous supposition is assumed in India where more stress is given to consumer well being. In spite of these common roots, a correlation between Indian, US and UK Law dissimilarity is found in their association between trademark law and comparative advertising law.

Meaning of Comparative Advertising:

Comparative advertising in the US is characterized as 'advertising that contrasts another brands on impartially quantifiable characteristics or cost, and recognizes the option brand by name, representation or other distinctive information.² Foundationally, US comparative advertising law originates from Title 15 of the United States Code, essential government enactment which covers Commerce and Trade. Title 15 gives the Federal Trade Commission (FTC) supervision over trade custom.

Title 15 particularly denies 'unjustifiable techniques for rivalry in or influencing trade, and unfair or deceptive acts or practices in or influencing business....'³ it likewise disallows false advertising.⁴ The Lanham Act, which sets out government assurance and enlistment principles for trademarks and is Title 15, precludes 'false designations of origin, false descriptions, and dilution.' Prior to the FTC's codification of US comparative advertising law, inquirers frequently depended upon the Lanham Act for relief.

The present condition of US comparative advertising law has been moulded and characterized by the FTC's Statement of Policy Regarding Comparative Advertising. This strategy proclamation, in actuality since 1979, stresses that the FTC endures, as well as effectively supports, honest, non-deceptive comparative advertising. The FTC's expressed perspective on the other hand, was that such promotion offers critical data to consumers and encourages product enhancement and improvement.⁵

According to FTC, comparative advertising is defined as

"an advertising that compare alternative brands on objectively measurable attributes or price, and identifies the alternative brand by name, illustration, or other distinctive information".⁶

Comparative advertising in the European Union (EU) is defined as 'any advertising which explicitly or by implication identifies a competitor or goods or services offered by a competitor.'⁷ Directive 2006/114/EC of the European Parliament and of the Council of 12 December 2006 Concerning Misleading and Comparative Advertising builds up this definition and sets down uniform general standards to blend the states for utilization of comparative advertising in the European Union member states. It is an order, and not a regulation; accordingly it permits EU member states to pick the structure and proper strategy by which to accomplish those targets in their own national laws.⁸ The UK is one of the Member States of the EU, which viewed comparative advertising as lawful before the EU Directives regulating misleading and comparative advertising were implemented.⁹

From the statutory perspective the expression 'comparative advertising' has not been characterized any place in both the UK's Trade Marks Act 1938 and Trade Marks Act 1994. Be that as it may, the same has been characterized statutorily in Section 2(1) of the UK's Business Protection from Misleading Marketing Regulations 2008 as

'advertising which in any way, either explicitly or by implication, identifies a competitor or a product offered by a competitor'.¹⁰

The idea of comparative advertising is fairly novel to India, and less settled. It has not been a piece of social customs for a considerable length of time as it has been for US neither it has any committed enactment or heading like in UK. In spite of the fact that India has no specific regulation regarding to comparative advertisement like USA, UK, yet to some degree, Monopolies of Restrictive Trade Practices Act, 1984(Now stand repealed) and the Trade Marks Act, 1999 discuss issues relating to lawful comparative advertisement. A competitor has a right to promote its product making praise about its quality¹¹ yet he can't put down the product of his rival. Additionally it has even been set around the different legal proclamations that a tradesman is qualified to pronounce his products to be the best or superior to anything his rivals', however, while proclaiming so he can't say that the goods of his rivals are awful to puff and advance his goods.¹² None of the statutory provision or judicial pronouncement clearly defined comparative advertising.

Analysis:

As shown above, in all India, U.S. and U.K, comparative advertising is legitimate when it is honest and non-deceptive. There is no clear–cut definition of comparative advertising in India. It is important to give a meaning to Comparative advertising in our lawful system as this will assist traders to sketch a line between lawful comparative advertising and deceptive or misleading comparative advertising. What's more, this would permit merchants to be more adaptable in their promotional activities and would make a reasonable focused environment between undertakings.The meaning of comparative advertising in English law could be utilized as a beginning stage for the Indian law.

Analysis of Law Regulating Comparative Advertising in USA, UK and India¹³:

This section will recapitulate the legal provisions with reference to the extent of trademark protection in comparative advertising or when the trademark is used by a third party without the approval of the trademark proprietor.

Legislative Background in the United States of America:

In USA self regulatory code of conduct, federal and state law together deals with law relating to comparative advertising. These are:

I. National Advertising Division

II. The Federal Trade Commission 1914

III. Section 43(a) of the Lanham Act 1946

One of the important forums to regulate advertising and to uphold consumer faith in advertising is the National Advertising Division of the Better Business Bureau (the "NAD"). It was basically a self-regulating body that gives a chance to the opponent and the consumer to oppose the truthfulness and honesty of a commercial and resolve the related issues effectively. The NAD would take up only those advertisements that are in the interest of public and is not subject to any pendency in court. As the competitor file a case in NAD the opponent has to withdraw the said commercial with immediate effect or give in writing that similar ads would not be run. Only in such cases NAD will not proceed to take further action. In case the modification is not done within the stipulated time NAD would re-examine the material submitted by the parties and give the necessary judgment. If the parties are not satisfied they can file an appeal to NARB.

Lastly the only statutory authority to deal with comparative advertising is Section 43(a), Lanham Act, 1946. The main purpose of the Act is to protect the trademark owner from the unlawful use of their trademark that is expected to cause consumer confusion or deception.¹⁴ The Act permits any person probable to be harmed by other person's wrongful or deceptive representations in an advertisement or inappropriate use of a trademark to take legal action in federal court, seeking injunctive relief, damages and, in rare cases, attorneys' fees. In the case of Smith v. Chanel¹⁵, the court laid down important principle on comparative advertisement. The Court of Appeals for the Ninth Circuit stated that comparative advertising should not be barred under the Lanham Act provided that it is not deceptive and does not create a probability of confusion among consumers.

Legislative Background in the United Kingdom:

In UK law on comparative advertising is based on the European Union Directions. The key forums to regulate comparative advertising are:

I. Trademark Act, 1994 (Section 10(6))

II. Comparative Advertising Directives

The use of trademarks in comparative advertisements is managed by two European Directives in the United Kingdom. The primary Directive is Council Directive 84/450/EEC, as modified by Directive 97/55/EC, relating to deceptive and comparative advertising ('Comparative Advertising Directive'). This was put into practice in UK by way of the Control of Misleading Advertisements Regulations. The subsequent Directive is Council Directive 89/104/EEC which provides the laws to the member nations of the European Union in relation to trademark law and the same is executed in UK as Trade Marks Act 1994.

Safeguard against comparative advertising is given only if the registered trademark is used with reference to the authentic goods or services of the owner and such utilization is equivalent with honest practice, to be precise is just and reasonable. In case this is not the situation, than all such comparative commercial would be considered as infringement of registered trademark if it is use which takes advantage of or is detrimental to the distinctive nature or reputation of the registered trade mark.¹⁶

Therefore only such cases of comparative advertisement are considered as infringement of trademark that does not adhere to the principle set in Comparative Advertising Directives. The Misleading and Comparative Advertising Directive are put into effect by permitting the interested parties to either take lawful action against the commercial or else to take the promotion before an executive authority who can settle on a grievance or start trial procedure. In the UK, the said Directives are implemented¹⁷ by local enforcement establishment, i.e., Trading Standards and the Office of Fair Trading. The trademark holder might also put the case before Advertising Standards Authority under the voluntary codes of conduct.

Legislative Background in India

In India, the legislation applicable to comparative advertising is:

I. The Trademarks Act 1999;

II. The applicable ASCI Guidelines.

The idea of comparative advertising takes form after the pleasant union of the MRTP Act 1984 and the Trademarks Act of 1999. The Trade Marks Act 1999 was a stimulating modification in the area of comparative advertising whose provisions are inspired by the UK Trade Marks Act, 1994.

Section 29 of the Trademark Act 1999 talks about the infringement of registered Trademark wherein, section 29(8) particularly states that a registered Trademark is infringed by any advertising of that Trademark if the promoter takes undue gain and is against the fair practice, if this advertising will be dangerous to the distinctive nature of the Trademark or is against the reputation of the Trademark.

Section 30(1) additionally supplements that nothing under section 29 will avert any advertiser or corporation from using another's Trademark provided it is utilized as a part of legitimate and reasonable practice in commercial and business matters and ought not to influence the distinctive character and repute of the Trademark.¹⁸ The Trade Marks Act, 1999 is an effort to stabilize the contradictory interests of the rights of registered trade mark owners and a convincing consumer interest in informative advertising.¹⁹

Obviously the Trademark Act, 1999 responded to the matters which the MRTP Act, 1969 was unable to answer with respect to the use of registered trademark. The Trade Marks Act (after its amendment in 1999) was more dynamic by nature and obviously managed the issue of the extent of obligation in comparative adverting during an era when the Indian economy has seen a boom with the business sectors opening up as a part of liberalization of trade and business and worldwide business interaction in the international economic situation with more brand proprietor inflowing the Indian market. The MRTP Act was somewhat more rigorous in methodology as it principally managed the issue of puffing or disparagement merely so long as the goods puffed or disparaged were identifiable as setting a connection with the key product to the public or the consumers at large.²⁰

In addition to that, Section 30(2) (a) of the Trademarks Act, 1999 too permitted the utilization of registered trademark in connection to the goods or services which are suggestive of the class, quality, amount, expected reason, esteem, geological origin and so forth. The above stated provisions are similar to Section 10(6) and Section 11(2) of the UK Trademarks Act, 1994.

Aside from the aforementioned statutes with reference to the law relating to comparative advertisement in India, the guidelines of "Advertising Standards Council of India (ASCI)" determines that comparative advertisement is acceptable if the facet of the products evaluated are clear, accurate and considerable, such correlation does not present false reward on advertiser, there is no unjustifiable denigration of the contending item and is unrealistic to delude the buyer.²¹

Analysis:

It is seen that the law relating to comparative disparaging advertisements is quite a recent expansion in India.²² At present, there is no fundamental legal agency or uniform enactment regulating the advertising business.²³ A scrutiny into the law governing comparative advertising in India uncovers that without a committed administrative component directing the same, a generally crude approach has been pursued, with varied facet of the same being resolved with reference to conflicting measures. Such a methodology is inadequate on a reasonable premise, as the particular utilization of assorted laws deserts a trail of lacunae in any endeavour to decide the question in an inclusive way.²⁴ Conversely UK have particular route in the form of the European Community (EC) Directive on Misleading Advertising relating to comparative advertising. While in US the two noteworthy regulations that deal with comparative advertising are Federal Trade Commission Act and the Trademark (Lanham) Act (the federal trademark statute prohibiting false designations of origin and false or misleading descriptions of facts).

Indeed, even the ASCI has possessed the capacity to guarantee a sensible level of adherence to its standards from members, a trouble emerges when grievance are documented with respect to the exercises of non-members. Besides, the lack of an efficient enforcement machinery to execute the said standards has resulted in them being restricted to a solely recommendatory role.²⁵ A contrast may be drawn between this non-implementable model of selfregulation and similar instrument that have been initiated in other jurisdiction.

The start of the self-administrative methodology in Britain was made in compatibility of a searing prosecution of the advertising business by the Monoley Committee on Consumer Protection, 1962, which suggested the controller for the business. Under the risk of external regulation, the industry considered the foundation of a self-administrative instrument much similar to the Press Council, which may fulfill the worries of policymakers and purchasers alike. The Advertising Standards Authority (ASA) was recognized, with the purpose of ensuring that advertisements were 'lawful, civilized, truthful and honest. An essential contrast between the ASA and the ASCI is in the previous' capacity in guaranteeing the enforceability of its orders. The premise of the same is an understanding that the ASA has gone into with newspapers and journals to not convey any ad that it esteems to have ruptured the Advertising Code set out by it. Further, it might elude tireless instances of infringement to the Director General of Fair Trading, who has a statutory obligation to acquire injunctive action against false advertising. With respect to comparative advertising, the Code says that 'Advertisers should not unfairly attack or discredit other businesses or their products.' An instrumental part in building up the above system has been that of a European Union directive allowing comparative advertising in light of a legitimate concern for rivalry and public awareness. The main condition forced in that will be that the promotion ought not be deceptive and have to authentically contrast like with like.²⁶

In this way, the need of hour is a more exhaustive plan of regulation to permit the publicizing business to propose an expansive structure of comparative advertising wherein the interest of contender and customer can be protected. This might be finished by method for embracing the model as has advanced in Britain, with the standards as endorsed by the advertising body being lawfully enforceable.

Secondly in UK once the case is not determined in the courts within the country or in the case of any uncertainty with respect to specific parts of the case, it is eluded to the court of EU as the higher authoritative forum. This is a consequence of the endeavours inside the European Union to synchronize the various facets of laws. As a consequence of that, in spite of the way that the UK was having its own particular Trademark Act, 1994, the Directive 2006/114/EC and the First Council Directive 89/104/EEC dealing with the European Union laws keep on assuming a noteworthy part. Spilling out of that is the contention between the defenses set under the Directive 2006/114/EC and the Council Directive 89/104/EEC. Be that as it may, there is no such clash of laws in the Indian or the US jurisdiction as it is just represented by its own particular national laws and statutes thereto.

Comparative Analysis of Judicial Approach to Comparative Advertising in USA, UK and India²⁷.

There are different factors that are kept in mind by different courts in the US, UK and India while choosing whether a specific case falls inside the scope of the irregularity of comparative advertising or not.

It could be effectively said that the courts in US were more in support of comparative advertising as opposite to the UK (Before implementation of European Union Guidelines) and keep up a stronger standard in this respect. Indeed, even now in UK, comparative advertising is more firmly guarded than in the United States, regardless of the United Kingdom's reputation for being tolerant in this matter. However the courts in India, particularly now have demonstrated a more strict mentality towards the twin segment of comparative advertising i.e.; puffery and denigration.

To what extent comparative advertising is permitted:

A standout amongst the most astonishing difference amid the approach to comparative advertising in the United States, UK and India is the assertion that the contender is allowed to say for all intents and purposes anything in regards to the brand which is the subject of examination gave that it is honest and does not give rise to confusion as to origin under their respective statutory legislation.

In USA, comparative advertising is allowed if it is honest, truthful and non-deceptive. Secondly the advertisement should not give rise to confusion as to origin of the trader or his goods.

In UK, there is a sturdy opinion to guard the goodwill connected both with a reputable trademark and the goods per se such that such commercial that tried to exploit the positive traits of a brand primarily to benefit from the reputation of the trademark of a opponent (i.e., to "obtain a free ride") are not permitted²⁸. Hence as indicated by the UK enactment comparative advertising permitted just on the off chance that it is not deceiving, contrasts like and like, does not create confusion, disgrace or take unfair advantage of an opponent trademark or present goods as impersonations of those bearing an ensured protected trade name.²⁹

In India, position in connection to above has not been distinctly expressed. Indian lawyers and courts should be called upon to decide rules on publicizing and comparative advertising which is catching in India. The above guiding principles have to be intensely swotted for managing section 29(8), Trademark Act, 1999 furthermore for use of common law to advertising.

In Reckitt & Colman of India Ltd. v. M.P. Ramachandran and in Reckitt & Colman v. Kiwi TTK³⁰ the court after analyzing various cases on the topic abridged the law as follows:

I. A tradesman is entitled to declare his goods to be the best in the world, even though the declaration is untrue.

II. He can also say that his goods are better than his competitor's, even though such statement is untrue.

III. For the purpose of saying that his goods are best in the world or his goods are better than his competitors he can even compare the advantage of his goods over the goods of others.

IV. He, however, cannot while saying that his goods are better than competitors, say that his competitors' goods are bad. If he says so, he really slanders the goods of his competitors. In other words, he defames his competitors and their goods which are not permissible.

V. If there is no defamation to the goods or to the manufacturer of such goods, no action lies, but if there is such defamation, an action lies and if an action lies the recovery of damages, then the court is also competent to grant an order of injunction restraining repetition of such defamation.

However said guidelines were again re-examined in the Dabur case. It was observed by the court that' a tradesman is entitled to declare his goods to be the best or better than his competitors' is no longer considered as 'good law'. While boosting about his goods he cannot say the goods of his competitors are bad so as to puff and promote his goods. Hyped up advertisement is permitted but they should not cross the grey area of permissible assertion and if they do so then there should be a rational basis for such declaration. It is not allowed to make superlative claims without any preparation.³¹

Comparative advertisement which does not discredit or denigrate the trademark of the contender does not sum to disparaging the latter's goods. Despite the fact that the utilization of a registered trademark in comparative advertising amount to infringement and the offended party is qualified for interim injunction against the defendant, in any case, where the censured commercial neither uses the trademark of offended party in the course of trade nor in any way recommend the association of offended party's trade mark with respondent's merchandise, offended party would not be qualified for injunction.³² The case of Grand Chemical Works v. Nirmala Dyechem³³ presents an analogous situation in which injunction was declined as the defendant's commercial did not hold any disparaging comments with regard to plaintiff's product. Also In Paras v. Ranbaxy,³⁴ Paras assumed trade mark infringement. Quoting Advanta and British Airways, Ranbaxy adduced a puffing argument and pleads commercial integrity. Nevertheless, the Gujarat High Court held that the commercial was 'disparaging and denigrating', MOOV, hence infringing Paras' trade mark. In Procter & Gamble v. Unilever,³⁵ the Calcutta High Court passed an interim injunction order restricting Unilever from asserting that its Rin detergent has given more 'whiteness' than Tide Naturals. Unilever was in fact signifying that commercial truthfulness could nullify accusation of denigration. Nevertheless, the Court made the observation that opponent products could not be 'proclaimed bad or rubbished'.

These two precedents have interwoven denigration and disparagement and set a standard of high edge for business genuineness, viably conveying the Indian Trademark Act closer to the Trademark Act (in its post-CAD avatar). Along these lines, in both Britain and India, the extent of comparative advertisements has been incredibly decreased.³⁶

REFERENCE:

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2. Statement of Policy Regarding Comparative Advertising, 16 C.F.R. § 14.15(b) (2012).

3. 15 U.S.C. § 45.

4. 15 U.S.C. §§ 52-54.

5. John E. Villafranco, 'The Law of Comparative Advertising in the United States', IP Litigator, Jan.-Feb. Pg. 1(2010).

6. As provided in Statement of Policy Regarding Comparative Advertising available at https://www.ftc.gov/publicstatements/ 1979/08/statement-policy-regarding-comparative-advertising (Last visited on Apr.12th 2016)

7. Directive 2006/114/EC, OJ L 376 at 22, art. 2(c).

8. Directive 2006/114/EC, OJ L 376 at 22, Para. 20.

9. Brunhildesteckler Steckler and Frank Bachmann, "Comparative Advertising in Germany with Regard to European Community Law", 10 E.I.P.R (1997), pp.578-586, at p.578.

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12. See of Reckitt & Colman of India Ltd. v. MP Ramachandran & Anr, 1999 PTC (19) 741, See of Reckitt & Colman of India Ltd. v. MP Ramachandran & Anr, 1999 PTC (19) 741

13. The detailed approach of law is discussed in the earlier chapter.

14. 15 U.S.C. § 1052(d) (1996).

15. Smith v. Chanel 402 F.2d 562, 159 U.S.P.Q. (BNA) 388 (9th Cir. 1968).

16. See Section 10 (6) of the Trademark Act,1996.

17. In UK the provisions on comparative advertising under Misleading and Comparative Advertising Directive are being put into practise by the Business Protection from Misleading Marketing Regulations 2008.

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25. Tata Press v. Mahanagar Telephone Nigam Ltd., (1995) 5 SCC 139.

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30. 63 (1996) DLT 29

31. Dabur India Limited v. Emami Limited (2004) 29 PTC 1 (Del).

32. Pepsi Co. Inc v. Hindustan Coca Cola Ltd. (2003) 27 PTC 305.

33. 2003(27) PTC 27 (Del).

34. (2008) AIR Gujarat 94.

35. C.S. No. 12 of 2010, Calcutta High Court, as available at https://indiankanoon.org/doc/114867153/(Last visited on Apr.14th 2016)

36. Arpan Banerjee, "Comparative advertising and the tort of generic disparagement", Journal of Intellectual Property Law & Practice, Vol. 5, No. 11 (2010).

Received on 14.08.2018 Modified on 16.10.2018

Int. J. Rev. and Res. Social Sci. 2019; 7(1):57-63.

DOI: 10.5958/2454-2687.2019.00003.0