Gujarat Bottling Co. Ltd. v. Coca-Cola Co.
Rule established
Affirmed the Dalpat Kumar three-condition test for temporary injunction. Added that while deciding balance of convenience, the court must weigh relative hardship to each party. Status quo has evidentiary weight but is not determinative.
Facts
- A commercial dispute between bottling company and brand owner regarding franchise/distribution rights
- One party sought temporary injunction to maintain the status quo during litigation
- The question was how "balance of convenience" should be assessed
Issue
- How should the court assess "balance of convenience" in the three-condition test for temporary injunction?
Held
- The Dalpat Kumar test (prima facie case + balance of convenience + irreparable injury) is affirmed
- Balance of convenience requires weighing relative hardship to both parties
- The court asks: who suffers more if the injunction is granted vs refused?
- Status quo has evidentiary weight (the existing arrangement is presumptively fair) but is not determinative
- The court exercises equitable discretion, no mechanical application
Ratio Decidendi
Balance of convenience = relative hardship analysis. Status quo carries weight but doesn't automatically decide. The court weighs harm to both parties in granting vs refusing.
How to use it in an exam
- Key line: "In Gujarat Bottling v. Coca-Cola (1995), the Supreme Court affirmed Dalpat Kumar and held that balance of convenience requires weighing relative hardship. Status quo is relevant but not determinative."
Source
Source: (1995) 5 SCC 545; verified via standard CPC references
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.