Burger King established in the year 1957, is an American multinational chain of hamburger fast food giant. Burger King owns all the rights extensively in relation to the use of the mark “BURGER KING” in conjunction with its distinctive logo which has evolved over the years. Burger King also owns 1040 domain names registered in its name.

In, 2014 Burger King entered the Indian markets and ever since has over 250 restaurants across India.

Source – Judgement

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

Cause of action arose when Burger King came to know about the existence of the websites namely, www.burgerkingfranchises.in & www.burgerkingfranchises.co.in and the fact that Mr. Swapnil Patil & others (infringers) were duping unsuspecting general public into believing that they were representatives of Burger King India Limited (which was the former name of the Burger King’s Indian Franchisee).

Hence, Burger King approached Delhi High Court to restrain the infringers from infringing their well-known and registered mark “Burger King”, misrepresentation and brand tarnishment.

Burger King submitted that the infringers were engaged in registering misleading domain names incorporating the "BURGER KING" marks and operating fake websites, thereupon and invited the general public to apply for franchises. It was further submitted that the infringers had also approached the general public as employees of the Burger King’s Indian Franchisee and, moreover fraudulently duped people of thousands of rupees by claiming to offer them Burger King Franchises in the form of cafés, lounges as well as restaurants. Burger King also claimed violation of its registered marks - "BURGER KING", BK and the Crescent Design Logo, as well as photographs of Burger King's international restaurants, in order to lure potential victims.

Burger King contended that that the infringers operated in an extremely clandestine manner and had not provided their accurate contact details on their website. In fact, the address provided on the website was that of Burger King India Limited itself, which was clear misleading of consumers into believing an association or that such activity was authorized by Burger King. Burger King claimed that such illegal acts not only harmed its goodwill and reputation but also jeopardized public interest.

Hence, the Delhi High Court granted an ex-parte ad interim injunction in favour of Burger King and restrained the infringers accordingly. The Court also ordered the domain name registrar to provide the contact details of the infringers, as well as restrict and block the access to those websites.

A SIGN IN A SHOE REPAIR STORE IN VANCOUVER READs:

We will heel you.

We will save your sole.

We will even dye for you.

A SIGN ON A BLINDS AND CURTAIN TRUCK:

“Blind man driving.”

Ralph Lauren Corporation (“Polo”) is a global leader in the design, marketing, and distribution of premium lifestyle products, including apparel, accessories, home, fragrances, and hospitality. Polo is the registered proprietor of the mark ‘POLO SPORT’ since 1967, which is registered in India and also declared a ‘Well-known’ trademark in 2011. Polo also owns the device mark which consists of a horse with a person riding it while flinging his club to hit a ball in the sport of polo.

Polo came across an application for copyright registration under ‘artistic work’ filed by Mr. Sandeep Arora, (Arora) who is engaged in the perfumery business. Polo noted that the mark registered by Arora bore several similarities with its mark since Arora had misappropriated the words ‘Polo’ and ‘Sport’ in their entirety. The only distinguishing feature in Arora’s mark was that four horses with riders playing the polo game were added compared to Polo’s mark which has one horse with a rider playing polo.

Polo thus approached the Hon’ble Delhi High Court and filed a rectification petition seeking removal of the registration made by the Ld. Register of Copyright in respect of impugned artwork under the name of ‘SPORTS POLO’.

Polo contended that Arora had infringed Polo’s literary and artistic copyright by tweaking the material form of Polo’s registered mark with which people recognize the famous Polo brand. Polo further contended that the four horses with riders, being the only distinguishing factor in Arora’s mark could not qualify as an original artistic work. Against this, Arora countered stating that his mark ‘ARRAS SPORTS POLO’ was substantially different as well as distinct from that of Polo for the following reasons:

i. There were four horses with four riders on their respective horses;

ii. The riders were not playing the sport of polo.

He further stated that the mark was used for their perfumery business since 2020 which was in no way associated with that of Polo’s businesses.

The primary issues for consideration before the Court were –

1. Whether registration granted in favor of Arora should be canceled?

2. Whether Arora’s copyright was an “original” artistic work?

Source – Judgement

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

The Court observed that, while comparing two marks, qualitative differences ought to be given preference over quantitative differences. In the present matter, Arora’s mark had a striking resemblance to Polo’s mark. Since, Arora’s copyright was not an original artistic work under the provisions of the Copyrights Act, 1957 and hence Polo was entitled to maintain the petition.

The Court further held that, under Section 45(2) of the Copyrights Act 1957, the Registrar of Copyrights has to hold an inquiry ensuring that, no trademark should be identical and/or deceptively similar to any artistic work which has been registered under the Trademarks Act. In the present case, the Court pointed out a loophole in the registration of Arora’s mark wherein the Copyright Registry had failed to act in terms of Section 45 of the Act as a search would have indicated the similarity between the Polo’s registered marks, in respect of which the copyright also existed.

In support of the foregoing, the Court referred to the case of Marico Ltd. vs. Mrs. Jagjit Kaur, 2018 SCC Del 8488 which dealt with the issue of rectification of copyright. It was observed in the case that, any entry made of a work that was not original would be an entry wrongly made in the Register. Further, a copyright registration could only be granted to original artistic works, and copyright registration could not be granted to outcomes that were reproductions or imitations of other original works.

Thus, the Court allowed the petition and directed the Registry of Copyrights to cancel Arora’s copyright registration of ‘SPORTS POLO’ within eight weeks from the date of the Order.

Trivia

The King of Hearts is the only king without a moustache.

American Airlines saved $40,000 in 1987 by eliminating one (1) olive from each salad served in first-class.

The Hon’ble Delhi High Court, in the matter of Vishal Pipes Limited v. Bhavya Pipe Industry, was dealing with an appeal challenging the Order dated 28th January, 2022 passed by the Ld. Additional District Judge (ld. ADJ), New Delhi in the suit wherein a permanent injunction was sought by Vishal Pipes Limited against Bhavya Pipe Industry for infringing its registered mark "VPL INDIA" and copyright as well as seeking reliefs for passing off, delivery up, rendition of accounts, etc. The grievance of Vishal Pipes Limited was that the ld. ADJ had refused to grant an ex parte order of injunction and had also failed to appoint a Local Commissioner for the seizure of the alleged infringing products.

When the matter was listed, the Court noticed that in order to avail the remedies provided under the various IPR statutes, a plaintiff has to usually institute a suit before a District Judge (Commercial) valuing it at Rs. 3 lakhs or above, as well as pay the basic required Court fee to invoke the jurisdiction of the said Court. However, the present Order which was challenged was passed by the ld. ADJ who was not designated as a Commercial Court.

Upon enquiring the same, the Court was informed that the suit was valued below Rs.3 Lakh and therefore, in view of the pecuniary provisions in the Commercial Courts Act, 2015 ("CCA"), where the 'specified value' for 'commercial disputes' is Rs. 3 Lakh read with Section 134 the Trade Marks Act, 1999 where a suit relating to trademarks is to be filed and adjudicated only by a District Court (Commercial), was adjudicated by a District Judge, (Non Commercial)

The logical corollary of this is that the provisions of the CCA also are not made applicable to such a suit. The Court found this situation to be quite peculiar since the plea raised the following two questions:

i. Can IP suits be valued below Rs.3 lakhs and be listed before the District Judges who are not notified as Commercial Courts?

ii. Whether the provisions of CCA would be applicable to such disputes?

It was brought to the Court's attention that litigants and lawyers, in order to escape the clutches of the provisions of the Commercial Courts Act were valuing the suits below Rs.3 lakhs and placing a large number of IP matters before the ld. ADJ (non-commercial) in Delhi. The Court observed that if such valuation was permitted, it would defeat the very purpose of the enactment of special provisions for IPR statutes and the CCA. These statutes have to be construed harmoniously i.e., in a manner so as to further the purpose of the legislation and not defeat it. Hence, it is mandatory for IP suits to be ascribed a 'specified value', in absence of which, such a valuation would be arbitrary, whimsical, and wholly unreasonable.

The Court further observed that there exist three classes of adjudicating courts for IP matters depending upon their value:

. Suits valued below Rs. 3 lakhs to be adjudicated by District Judges (Non-Commercial);

. Suits ranging between Rs. 3 Lakh and Rs.2 Crore to be adjudicated by District Judges (Commercial);

. Suits valued above Rs. 2 Crore to be adjudicated by the Commercial Division of the High Court (Original Jurisdiction).

In light of the above, considering that some value has to be given to the subject matter of the dispute the Court had to consider as to how should the concept of 'specified value' be analysed? Since there were no specific parameters for valuation, the Hon’ble Court, relied on past precedents and the appropriate provisions of law, summed up the legal position, and observed that, Courts would have to take into consideration the 'specified value' based not merely upon the value of the relief sought but also the market value of the intangible right which usually is trademarks, rights in copyrightable works, patents, designs involved in the said dispute. The Court made it clear that valuation of suits should be reasonable and that the plaintiff cannot deliberately undervalue the relief; if the valuation submitted by the plaintiff is arbitrary or unreasonable, Courts may reject the same; Plaintiffs ought to also provide justifiable reasons as to not providing the exact value of the relief.

The Court took a grim view regarding parties who deliberately undervalued the suits and addressed that, “the amount of Rs.3 lakhs was the estimation of the legislature as being the lowest threshold in any 'commercial dispute' in India which deserved to benefit from speedier adjudication, owing to the economic progress in the country. However, this intent of the Legislature in keeping a lower threshold in a 'commercial dispute' of Rs.3 lakhs cannot be rendered meaningless. It would only be in exceptional cases that valuation of IPR disputes below Rs.3 lakhs could be justified.”

In this backdrop, the Court held the following:

The Court made it clear that litigants, as well as lawyers, cannot escape the provisions of the CCA by valuing suits below Rs. 3 lakhs. All IPR suits which are to be instituted before District Courts, would, therefore, now first be instituted before the District Judge (Commercial).

1. In cases of IP suits valued below Rs. 3 lakhs, the specified value, and valuation of the same shall be examined by the Commercial Court in order to ensure it is not arbitrary, unreasonable, and/or undervalued.

2. Upon such an examination, the concerned Commercial Court may pass appropriate orders directing the plaintiff to amend the plaint in accordance with law and pay the requisite Court fee or issue directions to proceed with the adjudication of the suit as a non-commercial suit.

3. In cases wherein the suits which are valued below Rs.3 lakhs and continue as non-commercial suits, the same shall continue to be listed before the District Judge (Commercial) as well, however, may not be made subject to the provisions of the CCA in order to maintain consistency and clarity in adjudication.

4. All the pending IP suits filed before different District Judges (non- Commercial) in Delhi till now shall be placed before the concerned Commercial District Judges in Delhi in order to follow the foregoing procedure. However, the Court permitted the plaintiffs who wished to amend their Plaints in accordance with law.

The Court also directed that copies of the judgment to be sent to the Registrar General in order to be sent to all District Courts for necessary action.

A Geographical Indication (GI) tag is a sign/mark allotted to an artefact or a commodity that originates in a particular region and has its own unique identity. A GI right empowers the bearer to restrict the indication from being used by any other person whose quality does not meet the required criteria. In India, Geographical Indication tags are governed under the Geographical Indication of Goods (Registration and Protection) Act, 1999.

Kashmir Saffron

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

Saffron is renowned globally as a spice which is used in medicines and cosmetic products. It is believed that the Saffron was first cultivated in Kashmir by Central Asians around 1st Century BCE. It has also been mentioned in ancient Sanskrit texts and Saffron was referred as “Bahukam”.

Recently, Kashmir Saffron which is generally harvested in Karewa village of Jammu and Kashmir has been given Geographical Indication (GI) tag by the Geographical Indication Registry of India. Saffron is also grown in Budgam, Pulwama, Kishtwar and Srinagar districts of Jammu and Kashmir. Out of which Pampore village in Pulwama is known as the Kashmir’s “Saffron town” as the best quality of Saffron is cultivated here.

The GI application was filed by the Directorate of Agriculture, Government of Jammu and Kashmir, and initiated by the Sher-e-Kashmir University of Agriculture Sciences and Technology, Kashmir, and Saffron Research Station.

Kashmir specialises in three type of Saffron namely “Lachha Saffron”, “Mogra Saffron” and “Guchhi Saffron”. Kashmir Saffron has been associated with its natural deep-red colour, high aroma, chemical-free processing, and high quantity of colouring strength along with its flavour and bitterness which makes it unique from all other saffron.

Saffron farming employs 30,000 families in the area.

Manipuri Black Rice

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

Manipuri Black rice is known for all over the globe for high nutrient value. The Black rice is used in various traditional medicines along with that it has a unique gluten-free nature. The Black rice of Manipur is called by different names in different regions of the state such as Chak-Hao, Gorakhpur Terracotta and Kadalai Mittai of Kovilpatti.

The GI application was filed by the Consortium of Producers of Chakhao (Black Rice), Manipur and initiated by the Department of Agriculture, Government of Manipur and the North Eastern Regional Agricultural Marketing Corporation Limited.

Black rice harvesting is unique as it has deep black colour and is generally higher in weight due to anthocyanin agent. Black rice is mostly used for preparing desserts or porridge. The Black rice farming has been continued by the farmers over ages and is characterised by its special aroma.

The Delhi High Court recently restrained Crompton Greaves Consumer Electricals Limited from infringing the trademark "PEBBLE" on a suit filed by V Guard Industries Ltd. (V Guard).

V Guard manufactures and sells consumer electronics, electronic apparatus and instruments, parts and fittings etc. since 1977 across India, Nepal, Sri Lanka and UAE. V Guard owns the trademark/label "PEBBLE" in Class 11 for electric water heaters, claiming a prior use since 2013. In 2021, V guard applied for the mark "PEBBLE" in Class 7 for electric irons and ironing machines, however the same was objected by the Trade Marks Registry.

Crompton Greaves Consumer Electricals Ltd. (Crompton) also manufactures and sells electronic appliances under the mark “CROMPTON GREAVES”. Crompton registered the mark “CROMPTON PEBBLE” in Class 8 in respect of electric irons; however the impugned registration is suspended for non-compliance of limitation period by the Trade Marks Registry.

V Guard was aggrieved when it discovered that Crompton was selling electric irons under the impugned mark “CROMPTON PEBBLE” infringed upon its mark with the intention to take advantage of its goodwill and repute. V Guard sent a legal notice to Crompton asking them to discontinue using the impugned mark. However, Crompton replied stating that there was no similarity of whatsoever kind between the two marks and hence there was no possibility of any confusion amongst customers.

Source – Judgement

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

V Guard thereafter approached the Delhi High Court claiming trademark infringement and passing off. V Guard argued that Crompton’s mark was phonetically, visually, structurally as well as deceptively similar in respect of competing goods which were sold through similar trade channels. V Guard further contended that it had been using the mark since 2013, as opposed to Crompton which was using the impugned mark since 2020. V Guard submitted that not only Crompton was selling its products on their website, www.crompton.co.in and e-commerce platforms such as Amazon, Flipkart but the products reflected only ‘PEBBLE’ instead of the impugned mark “CROMPTON PEBBLE”. In support of the foregoing, V Guard placed a few screenshots of the products being sold on the third party websites.

Against this Crompton countered stating that, it was using the impugned mark with the term "CROMPTON" as a source identifier in respect of dissimilar goods. Crompton further stated that the rival marks were completely different, while viewed in entirety, and V Guard, not being a registered proprietor of the mark “PEBBLE” with respect to specifically ‘electric irons’, could not sue for infringement nor claim any exclusive right thereto.

After considering the submissions, averments made and evidence placed on record by both the parties, the Court held that the term "PEBBLE" was an essential and the dominant part of V Guard’s registered label mark and Crompton’s stand regarding V Guard not being able to assert exclusivity over the word "PEBBLE" on the basis of pending registration in the label/device, could not be permitted.

The Court rejected Crompton’s contention that "CROMPTON" was being used as a source indicator, owing to absence of any pleadings regarding its extensive use and sales turnover in respect of electric irons being sold, and the fact that there exists no concept of ‘sub-branding’ in trademark law. However, the Court also rejected that the products sold were competing and similar but noted that V Guard was the prior user of the mark "PEBBLE" since 2013, as against that of Crompton in 2020.

As a result, a case of trademark infringement and passing off was made out and restrained Crompton from manufacturing, selling, advertising or dealing in electronic goods bearing the impugned mark.

Trivia

SHOWBOAT - These were floating theatres built on a barge that was pushed by a steamboat. These played small towns along the Mississippi River. Unlike the boat shown in the movie "Showboat", these did not have an engine. They were gaudy and attention grabbing which is why we say someone who is being the life of the party is "showboating."

OVER A BARREL - In the days before CPR, a drowning victim would be placed face down over a barrel and the barrel would be rolled back and forth in an effort to empty the lungs of water. It was rarely effective. If you are over a barrel, you are in deep trouble.

BARGE IN - Heavy freight was moved along the Mississippi in large barges pushed by steamboats. These were hard to control and would sometimes swing into piers or other boats. People would say they "barged in."

HOGWASH - Steamboats carried both people and animals. Since pigs smelled so bad they would be washed before being put on board. The mud and other filth that was washed off were considered useless "hog wash."

The Delhi High Court has restrained Panasonic Life Solutions India Pvt. Ltd. (Panasonic) from infringing the registered designs of Havells India Limited (Havells).

In March 2022, it came to the knowledge of Havells that Panasonic was to launch its new series of ceiling fans which was going to be branded as “VENICE PRIME”. It was observed by Havells that the fans sold under these series were deceptively similar and/or identical copies in entirety of that of Havells’ ENTICER and/or ENTICER ART ceiling fans.

As a result, Havells approached the Delhi High Court seeking to restrain Panasonic from infringing its registered designs bearing nos. 280666 (2016 Design - )and 328605 (2020 Design -) and manufacturing, selling and marketing its VENICE PRIME series ceiling fans.

Source – Judgement

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

Panasonic countered stating that, Havells’ 2016 Design was ought to be cancelled because Havells had claimed trademark rights by way of addressing its designs as ‘trademark’, ‘trade-dress’ and ‘source-identifier’ of its trade and business, in its plaint which was statutorily not allowed under the section 2(d) of Design Act, 2000 which defines “design” and states that anything that includes a trade mark cannot be constituted as a design. Panasonic further argued that, Havells’ 2016 Design was not novel but was merely a design derived from its previously launched ceiling fans and that Havells Design 2020 was dissimilar to that of its VENICE PRIME series.

Having stated this, a plausible question of invoking the common law remedy of ‘passing-off’ also arose as Havells had mentioned its already registered designs as ‘trademark’.

Against this, Havells, to prove the novelty of the Havells’ 2016 Design, placed a comparison table of the Havells’ 2016 Deisgn with some of the prior publications on record.

With regards to the two claims of passing off and infringement made by Havells, the Court observed that, the basic ingredient for passing off was misrepresentation, which, in this case, was not satisfied as no customer with an average intelligence and imperfect recollection would be deceived or confused into buying the fans of Panasonic under an impression that they were the goods of Havells. Hence, Havells was not able to establish the prima facie case of passing off in Design 2016.

Further with respect to the claim of infringement under section 22 of the Designs Act, the Court scrutinized the matter comparing the essential features of the designs. A visual comparison of the two fans showed that: (a). overall appearance and shape were similar; (b). the inner border of the motor body was plain which was outlining the bulge and seamlessly joined with the trim while the outer border part was continuously running from the blade trims to the body ring giving an effect that the trims/ornamentation body ring and bottom cover were seamless and one single unit, in both the fans; and (c). both fans had filleted corners on the blade tips which gave a symmetric appearance along with a depression that ran through the blades. Therefore, the Court held that Havells had made out a prima facie case of infringement of Design 2016 and that Panasonic’s VENICE PRIME series design was created with a clear intent to copy the Havells’ 2020 Design.

Accordingly, Panasonic, was restrained from manufacturing, marketing, selling (including upon the online platforms) the fans under its VENICE PRIME series and/or those which are identical or deceptively similar to the designs of the Havells or which are colorable imitation or substantial reproduction of Havells get-up, layout, trade dress, colour scheme, pattern, shape, configuration etc. in the ENTICER ART-NS Stone series during the pendency of the suit.

The matter is now, enlisted before the learned Joint Registrar on 02.08.2022.

Trivia

No piece of paper can be folded in half more than seven (7) times.

Donkeys kill more people annually than plane crashes or shark attacks.

You burn more calories sleeping, than you do watching television.

Oak trees do not produce acorns until they are fifty (50) years of age, or older. 

The first product to have a bar code was Wrigley's gum.

Under the Law on Patents in force in Cambodia, pharmaceutical products now stand excluded from patent protection [Article 4(iv) and Article 136 of the amended Law on Patents (Royal Kram Nº NS/RKM/1117/016)].

Article 136 - The pharmaceutical products mentioned in the Article 4 of this Law shall be excluded from patent protection until January 01, 2016, according to the Declaration on Agreement on Trade-Related Aspects of Intellectual Property Rights and Public Health of the Ministerial Conference of World Trade Organization dated November 14, 2001 in Doha of Qatar."

Under the Law on Management of Pharmaceutical promulgated by Kram No. ChS/RKM/0696/02 dated on June 17, 1996 and amendment adopted by the National Assembly of the Kingdom of Cambodia on November 8, 2007, a pharmaceutical is one or many kinds of substances which are primarily from chemicals, bio-products, microbes, plants combined in order to use in the prevention or treatment of human or animal diseases, or to use in the medical or pharmaceutical research or diagnosis, or change or support the functioning of the organs.

Accordingly, the following products shall be considered as pharmaceutical products and excluded from protection in Cambodia:

• Serum and vaccines,

• Blood or blood products,

• Traditional medicines,

• Products which are composed of poisonous substances, which are included in a list determined by Sub-Decree.

This waiver would also apply to the European, Singapore and Chinese patents providing protection for pharmaceutical products, for which validation is sought in Cambodia.

Furthermore, Cambodia currently benefits from the World Trade Organization waiver allowing Least Developed Countries (LDCs) in order to avoid granting and enforcing IP rights on pharmaceutical products until 2033.

Trivia

RIFF RAFF - The Mississippi River was the main way of traveling from north to south. Riverboats carried passengers and freight but they were expensive so most people used rafts. Everything had the right of way over rafts which were considered cheap. The steering oar on the rafts was called a "riff" and this transposed into riff-raft, meaning low class.

COBWEB - The Old English word for "spider" was "cob."

SHIP STATE ROOMS - Traveling by steamboat was considered the height of comfort. Passenger cabins on the boats were not numbered. Instead they were named after states. To this day cabins on ships are called staterooms.

SLEEP TIGHT - Early beds were made with a wooden frame. Ropes were tied across the frame in a crisscross pattern. A straw mattress was then put on top of the ropes. Over time the ropes stretched, causing the bed to sag. The owner would then tighten the ropes to get a better night's sleep.

- Provided by my good friend, Phil Furgang.

- Provided by my good friend, Phil Furgang.

I broke my finger last week. On the other hand, I’m okay.

******

What is the best thing about living in Switzerland?

Well, the flag is a big plus.

******

Did you hear about the guy who got hit in the head with a can of soda?

He was lucky it was a soft drink.

******

To the mathematician who thought of the idea of zero.

Thanks for nothing!

******

Son: "Dad, can you tell me what a solar eclipse is?"

Dad: "No sun."

******

Roxy

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

Quiksilver is a surfing-inspired apparel and accessories brand which was founded in 1969 in Torquay, Australia. In 1990, Quiksilver launched its sister brand for young women ’Roxy’.

Roxy was discontinued after the surf industry crash in 1991; however it was revived by Bob McKnight in 1992 by differentiating it from the main Quiksilver line.

There are two explanations for choosing “Roxy” as a name for the brand; firstly, the word Roxy brought a punk band or club to one’s mind and secondly, both Alan Green (Founder of Quicksilver) and Roxy’s CEO Bob McKnight have daughters named Roxy.

At a cursory glance, the Roxy logo may look like a stylized depiction of a heart. However, one takes a closer look; the heart is created by positioning two copies of the Quiksilver logo (one standard, the other one reflected) next to each other.

Thus, not only does the Roxy logo make a link with its parent brand but at the same time also creates a unique and romantic image which appeals to women.

-Adv. Chinmay Pawar

*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

The kingdom of the Satavahanas arose in the first century B.C. in the north-western Deccan on the ruins of the Mauryan Empire, with its capital at Pratishtana (modern Paithan in Maharashtra). The Satavahanas were assumed to have originated in the Andhra region (deltas of the Godavari and Krishna rivers on the east coast, finally establishing their power in the west) and hence was also known as the Andhra dynasty.

After half a century of political turmoil with the Shakas of the Kshaharata clan, the Satvahana Empire leapt into prominence under the reign of Gautamiputra Satakarni. He regained control of northern Maharashtra, Konkan region, Narmada valley, Saurashtra, Malwa, and the western Rajputana. It is also believed that he was greatly assisted by his mother. His achievements are recorded by his mother Gautami Balashri in an elaborate inscription called the ‘Nasik Prashasti’. According to historical sources, he reigned for at least 21 - 25 years.

The ‘Nasik Prashasti’ inscription calls him ‘Ekabrahmana’ which may be interpreted as 'a peerless Brahmin’, ‘the only protector of the Brahmins’ or ‘a proud champion of Brahmanism’. Nevertheless, the king was tolerant towards other religious sects and religions. He exempted Buddhist monks from paying taxes and granted immunity from any interference by the royal officers in their religious affairs.