Asha lives and carries on business in Delhi and owns an unregistered mark. She wants to sue Rohan, who…

Section 134(1)(c) brings passing off suits within the rule that they shall not be instituted "in any court inferior to a District Court having jurisdiction to try the suit". But section 134(2), which lets the plaintiff sue where she resides or carries on business, applies only "For the purpose of clauses (a) and (b)", that is, suits on registered marks. Asha's claim on an unregistered mark must therefore follow the ordinary rules of territorial jurisdiction.