Case Name: Lifestyle Equities C.V. & Anr. v. Amazon Technologies Inc.
Date of Judgment: October 07, 2025
Citation: 2025 INSC 1190, SLP (C) No. 19767 of 2025
Bench: Hon’ble Mr. Justice J.B. Pardiwala and Hon’ble Mr. Justice Ujjal Bhuyan
Held: The Supreme Court dismissed the special leave petition filed by Lifestyle Equities, refusing to interfere with the Delhi High Court’s order which granted Amazon Technologies unconditional stay of a massive ₹336 crore money decree and costs. It ruled that the provisions of Order XLI Rules 1(3) and 5(5) of the CPC are directory and not mandatory, and that appellate courts retain discretion to grant unconditional stay in exceptional cases.
Summary: The dispute arose from Lifestyle Equities’ suit against Amazon for trademark infringement of the “Beverly Hills Polo Club” (BHPC) mark. In 2025, the Delhi High Court’s Single Judge decreed the suit ex parte against Amazon, awarding damages of $38.78 million (₹336 crore) plus costs of ₹3.23 crore. Amazon appealed, and the Division Bench stayed execution of the decree without requiring a deposit, subject to Amazon’s undertaking to comply if it lost the appeal. Lifestyle challenged this before the Supreme Court, arguing that Order XLI Rule 5 CPC made deposit of the decretal amount mandatory for stay, and that the High Court erred in ignoring precedents such as Sihor Nagar Palika Bureau v. Bhabhlubhai Virabhai & Co.
Amazon countered that the High Court had rightly exercised discretion, pointing to defects in service of summons, lack of notice of enhanced damages, and legal infirmities in the decree. It relied on Malwa Strips Pvt. Ltd. v. Jyoti Ltd. and Kayamuddin Shamsuddin Khan v. SBI, which had interpreted the CPC provisions as directory.
Decision: The Supreme Court agreed with Amazon, holding that although deposit of decretal sums is ordinarily required as a matter of prudence, it is not an absolute legal mandate. Appellate courts retain discretion to grant unconditional stay in exceptional cases where substantial injustice or irregularity is apparent. Since the Delhi High Court had given cogent reasons and imposed an undertaking on Amazon, no interference was warranted. Accordingly, the SLP was dismissed, and the unconditional stay on the money decree was upheld.