Bombay HC Directs Haryana SP to Provide Police Protection After Court Receiver Assaulted During Unilever Trademark Raid
The Bombay High Court directed the Superintendent of Police, Ambala, to ensure police protection after a court-appointed receiver was physically assaulted while executing an anti-counterfeiting order at a Haryana premises.
Justice Shreeram V. Shirsat, sitting singly at the Bombay High Court, took up a deeply troubling report on 29 May 2026 after the Additional Special Receiver appointed in a commercial intellectual property suit filed by Unilever Plc was physically assaulted while attempting to execute an ex-parte ad interim order at a premises in Naraingarh, District Ambala, Haryana. The assault, which took place on 21 May 2026, involved the forcible removal of already-seized counterfeit goods, the snatching of mobile phones, and the pursuit of the execution team along the Ambala-Delhi Highway. The court directed the Superintendent of Police, Ambala, and the Station House Officer of Mahua Kheri Police Chowki to provide sufficient police protection, including lady police constables, for the next attempt to execute the order, and called for an action report on the assault.
The Underlying Trademark Enforcement Order
The Commercial IP Suit (L) No. 36456 of 2025 was filed by Unilever Plc against Ashok Kumar. Justice Sharmila U. Deshmukh had, on 24 November 2024, appointed the Court Receiver, High Court, Bombay, with all powers under Order XL Rule 1 and Order XXXIX Rule 7 of the Code of Civil Procedure, 1908, except the power of sale, and directed the receiver to seal and seize all impugned goods being used by the defendants in their business.
That order was extended on multiple occasions: 15 December 2025, 28 January 2026, 16 February 2026, 17 March 2026, and 4 May 2026. The Additional Special Receiver, Advocate Harshwardhan Joshi, was appointed by the court to carry out the execution on the ground.
What Happened at the Naraingarh Premises on 21 May 2026
On 22 May 2026, at around 11:30 AM, the Additional Special Receiver and the plaintiff's representative went to the SP office in Ambala and met the Reader to the SP, Mr. Ramesh Kumar, to inform him of the court order. The SP directed SHO Lalit Kumar of Naraingarh Police Station to provide police assistance. The SHO in turn directed ASI Surjit Singh of Mahua Kheri Chowki to assist the team.
The execution team reached the defendant's premises at Post Nanduwali Village, Naraingarh, at around 4:15 PM. The premises were locked; the team broke the locks in the presence of police assistance. Inside, the receiver found a large quantity of counterfeit goods bearing Unilever's trademarks, labels, and artwork. The premises appeared to function as both a manufacturing unit and a warehouse.
The counterfeit inventory documented on-site included approximately 1,500 finished pieces of POND'S BRIGHT BEAUTY cream, approximately 1,500 finished pieces of POND'S BRIGHT MIRACLE face wash, 24 gunny bags of empty 340 ml Dove Damage Therapy Hair Fall Rescue shampoo bottles, 35 gunny bags of empty 340 ml Dove Damage Therapy Intense Repair shampoo bottles, 51 large drums and 43 mini drums of raw materials for shampoo manufacturing, and approximately 33 gunny bags of outer packaging for Fair and Lovely, each containing approximately 1,500 pieces. The receiver described the counterfeit goods as “identical in appearance ditto-to-ditto” to Unilever's genuine products.
The Assault and Obstruction
While the team was loading the seized goods onto their truck, a white Mahindra Scorpio bearing registration number HR85J9881 and a black Toyota Fortuner bearing registration number HR01AX0707 arrived at the premises. Several individuals emerged from these vehicles and physically assaulted the Additional Special Receiver, the plaintiff's representatives, and the private security personnel accompanying them.
During the assault, the receiver's shirt was torn and mobile phones belonging to him and a representative of Hindustan Unilever Limited were forcibly snatched. The counterfeit material that had already been loaded onto the truck was unlawfully removed and taken back by the mob. The execution team was ultimately forced off the premises. Individuals identified during the incident included Mr. Neeraj Kumar Ahuja, Mr. Neeraj Verma, Mr. Akash, and Mr. Rajesh Choona.
The mob then followed the execution team in the same vehicles along the Ambala-Delhi Highway. Police assistance accompanied the team only up to the Ambala-Delhi Highway, despite requests for escort to the Haryana border. Along the highway, the counterfeiters intercepted the team's vehicle, threatened them, and forcibly confiscated the samples of counterfeit goods that had been secured, placing them under their own vehicle. This occurred in the direct presence of the police assistance.
The receiver called SHO Lalit Kumar on his mobile number but received no cooperation. He then called Superintendent of Police Ajit Singh Shekhawat at around 8:26 PM, requesting urgent police protection or escort to the Haryana border. According to the report, the SP responded with the remark “ye nautanki mat karo” and subsequently refused to answer further calls.
The receiver and the plaintiff's representative underwent a Medico Legal Case examination at Holy Family Hospital in Delhi at approximately 2:30 AM. Medical papers, photographs, and email communications addressed to the IG and SP Ambala were placed on record before the court.
The Court's Assessment
Justice Shirsat, on examining the report, the email, the medical papers, and the photographs, found it prima facie evident that the Additional Special Receiver and the persons accompanying him had been assaulted by Neeraj Kumar and his accomplices. The court noted that while the police had initially extended cooperation, they had failed to provide protection when the assault occurred and when the team was being pursued.
The court also noted that counsel for the plaintiff had drawn its attention to several other orders passed by the Bombay High Court in similar matters where court receivers or special receivers had been assaulted during execution. Justice Shirsat observed that such tendencies are “extremely despicable” and that no one should be permitted to take law into their own hands.
The court further noted that the report indicated the seized goods had been transferred to another location by the named persons. It directed that if the Additional Special Receiver and the plaintiff were able to identify the new location, police protection should be extended for execution there as well.
Directions Issued
The court issued the following directions:
The Superintendent of Police, Ambala, and the Station House Officer of Mahua Kheri Police Chowki are directed to ensure sufficient police protection, including lady police constables, is provided to the Additional Special Receiver and the plaintiff's representatives when they visit the premises to execute the ex-parte ad interim order. The police are directed to use reasonable and proportionate force to ensure the order is executed in its letter and spirit.
Police assistance is to be provided without any cost for the entire period during which the Additional Special Receiver, along with the plaintiff's representatives, executes the ex-parte ad interim order dated 24 November 2025 read with the order dated 4 May 2026.
The Superintendent of Police is directed to take action under law with respect to the assault on the Additional Special Receiver and the plaintiff's representatives on 21 May 2026, and to forward a report to the court about the action taken against the offenders.
The court expressed its expectation that SHO Lalit Kumar, ASI Surjit Singh, and SP Ajit Singh Shekhawat would look into the matter with the seriousness it deserves and ensure that the order dated 24 November 2025 is duly executed under their supervision.
On the question of adding Suresh, Rajesh, and Neeraj as defendants in the petition, the court noted that no draft amendment had been filed and directed counsel for the applicant to place a draft amendment on record if the plaintiff seeks to do so.
Order
The matter was stood over to 24 June 2026. The directions to the Superintendent of Police, Ambala, and the SHO of Mahua Kheri Police Chowki were issued with immediate effect. The court's order was passed on 29 May 2026 in Interim Application (L) No. 36579 of 2025 in Commercial IP Suit (L) No. 36456 of 2025, with Mr. Hiren Kamod, along with Niyati Davawala, Anil Shete, Nidhi Rao, and Chandrika Devda of Davawala and Co., appearing for the applicant, and Mr. Deepak Bhalerao, 2nd Assistant to the Court Receiver, present before the court.