George Payne & Co., [Ceylon] Ltd. v. International Exports [Pvt.] Ltd. – sllr 1998 volume 1 page 250

In the case of GEORGE PAYNE & CO., (CEYLON) LTD. v. INTERNATIONAL EXPORTS (PVT) LTD., the court addressed the issue of whether subsequent acts of alleged trademark infringement and unfair competition in the tea export market, occurring after a 1993 permanent injunction, constituted new causes of action or were subsumed under the earlier decree. It was held that subsequent infringing acts were merged within the prior judgment and did not constitute independent causes of action. This principle reaffirmed the doctrine of “merger in judgment” as applicable to continuing acts of infringement following a permanent injunction. The court relied on established legal doctrines and relevant precedents, emphasizing that the appropriate remedy lay in seeking relief for contempt or enforcement of the ex