Latest JudgementCode of Civil Procedure, 1908

Lifestyle Equities C.V. & Anr. v. Amazon Technologies Inc., 2025

The Court clarified the law on stay of execution of decrees, dispelling the misconception that deposit/security is always mandatory.

Supreme Court of India·7 October 2025
Lifestyle Equities C.V. & Anr. v. Amazon Technologies Inc., 2025
Code of Civil Procedure, 1908
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Judgement Details

Court

Supreme Court of India

Date of Decision

7 October 2025

Judges

Justice JB Pardiwala and Justice KV Viswanathan

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

  • Lifestyle Equities and Lifestyle Licensing filed a trademark infringement suit against Amazon Technologies Inc., Cloudtail India Pvt. Ltd., and Amazon Seller Services Pvt. Ltd. alleging sale of goods bearing deceptively similar marks.

  • Cloudtail admitted liability and was ordered to pay damages.

  • Amazon Technologies was proceeded ex parte due to service issues.

  • The Single Judge unexpectedly enhanced damages from ₹2 crore to ₹336 crore without pleading amendments.

  • Amazon appealed and sought a stay on execution of the money decree citing procedural and substantive flaws.

  • The Delhi High Court Division Bench granted stay without requiring deposit of the disputed amount.

  • Lifestyle challenged this stay before the Supreme Court.

Issues

  1. Whether deposit or furnishing security is a mandatory precondition for stay of execution of a money decree under Order XLI Rule 5 of CPC?

  2. Whether appellate courts have discretion to grant stay without deposit/security in exceptional cases?

  3. The scope and criteria for granting unconditional stay of execution of a decree?

  4. Whether failure to deposit decretal amount can lead to dismissal of appeal?

  5. Applicability of stay provisions uniformly to money and other decrees?

Held

  • Deposit or security is not an absolute condition precedent for stay of execution of a money decree.

  • Appellate courts possess discretionary power to grant stay even without deposit/security based on case facts.

  • The appellate court must record cogent reasons based on sufficient cause to grant stay.

  • Unconditional stays are rare and granted only in exceptional cases as defined by the Court.

  • No distinction exists between money and other decrees for stay provisions under Order XLI Rule 5 CPC.

Analysis

  • The Court clarified the law on stay of execution of decrees, dispelling the misconception that deposit/security is always mandatory.

  • Emphasized the discretionary nature of the power, aimed at balancing the interests of the decree-holder and appellant.

  • The judgment strengthens access to justice by allowing appellate courts to prevent injustice caused by flawed or extreme judgments, without forcing immediate deposit.

  • The criteria for unconditional stay set a high threshold to prevent misuse.

  • This decision harmonizes procedural rigor with judicial discretion, encouraging more nuanced adjudication in stay applications.

  • The ruling has significant implications for civil appellate practice, especially in commercial and money decree cases.