Delhi High Court Cancels ‘NAUKRIYAN’ Trademark, Holds It Deceptively Similar to Info Edge’s ‘NAUKRI’ Mark

Delhi High Court Cancels ‘NAUKRIYAN’ Trademark, Holds It Deceptively Similar to Info Edge’s ‘NAUKRI’ Mark

Introduction

The Delhi High Court has quashed the trademark registration of “NAUKRIYAN”, holding that it is deceptively similar to the mark “NAUKRI” used by Info Edge (India) Limited for its well-known employment portal Naukri.com.

Justice Tushar Rao Gedela held that the dominant feature in both marks is the word “naukri,” and that the plural form “naukriyan” does not create sufficient distinctiveness to avoid confusion among consumers, particularly when both marks relate to employment-related services.

Factual Background

Info Edge (India) Limited operates the well-known job portal Naukri.com and has been using the trademark “NAUKRI” and related domain names since 1997 for employment and recruitment services. The company challenged the registration of the mark “NAUKRIYAN”, granted in favour of Pradeep Namdeo, contending that it was deceptively similar to its well-established trademark “NAUKRI.” Info Edge argued that the word “naukriyan” is merely the plural form of the Hindi word “naukri,” meaning “jobs,” and therefore conveys the same commercial impression as its trademark.

Procedural Background

Info Edge filed an opposition before the Registrar of Trade Marks against the registration of “NAUKRIYAN.” However, by an order dated March 25, 2025, the Registrar rejected the opposition and permitted the registration of the mark in favour of the applicant. Aggrieved by this decision, Info Edge approached the Delhi High Court seeking quashing of the Registrar’s order and removal of the impugned trademark from the register.

Issues

1. Whether the trademark “NAUKRIYAN” is deceptively similar to the registered trademark “NAUKRI/NAUKRI.COM.”

2. Whether the Registrar of Trade Marks erred in permitting the registration despite the prior rights and reputation of the petitioner’s mark.

3. Whether the plural form of a word forming the dominant element of an earlier trademark can create sufficient distinctiveness to avoid confusion.

Contentions of the Parties

Info Edge contended that it was the prior adopter and registered proprietor of the “NAUKRI” mark and had built significant goodwill and reputation around the brand since 1997.

The company also relied on previous decisions of courts recognising “NAUKRI/NAUKRI.COM” as a distinctive and well-known trademark. It pointed out that courts had earlier restrained the use of similar marks such as “NAUKRIE.COM,” “NAUKRINEWS.COM,” “CVNAUKRI.COM,” “nownaukri.com,” and “Noukri.com.”

The Registrar of Trade Marks defended the impugned order, arguing that the marks were visually and phonetically distinguishable. It was submitted that the impugned mark was a stylised label with a distinctive colour scheme and tagline, which differentiated it from the petitioner’s mark.

Reasoning and Analysis

The Court examined the rival marks and observed that the dominant and essential element in both marks was the word “naukri.” The Court further noted that the applicant himself had admitted in the proceedings before the Registrar that the word “naukriyan” was simply the plural form of the Hindi word “naukri,” meaning job. In these circumstances, the Court held that the pluralisation of the word did not create sufficient distinctiveness to avoid confusion in the minds of consumers, particularly since both parties operated in the employment services sector. The Court also observed that in such cases, the rule of anti-dissection which requires marks to be compared as a whole would not prevent the Court from considering the dominant element of the marks. Accordingly, the Court held that the mark “NAUKRIYAN” was deceptively similar to the petitioner’s trademark and likely to mislead or confuse the public.

Decision

The Delhi High Court allowed the appeal filed by Info Edge (India) Limited. The Court quashed the order of the Registrar of Trade Marks dated March 25, 2025, as well as the trademark registration granted to Pradeep Namdeo. It further directed the Registrar to remove the impugned mark “NAUKRIYAN” from the trademark register within four weeks.

In this case the plaintiff was represented by Advocates Nikhil Sharma, Mehak Rahul Chaudhry, Akshay Bhardwaj and Hitesh Malik. Meanwhile the defendant was represented by CGSC Nidhi Raman with Advocates Om Ram and Nikita Singh.