Delhi High Court Injuncts Indian Firm From Using ‘SHRM’ Mark; Orders Blocking Of shrm.in Domain For Prima Facie Trademark Infringement

Delhi High Court Injuncts Indian Firm From Using ‘SHRM’ Mark; Orders Blocking Of shrm.in Domain For Prima Facie Trademark Infringement

Introduction

The Delhi High Court has granted an ex-parte ad-interim injunction in favour of the Society for Human Resource Management (SHRM), restraining Strategic HRM from using the “SHRM” trademark and related branding. The Court held that a prima facie case of trademark infringement and passing off had been established and that failure to grant interim protection would result in irreparable loss and injury to the plaintiff’s global reputation.

Factual Background

The Society for Human Resource Management (SHRM), originally established in 1948 in the United States as the American Society for Personnel Administration (ASPA) and renamed in 1989, is a globally recognised professional body in the field of human resources. The organisation claims a membership base of approximately 340,000 members across 180 countries and operates in India through its wholly-owned subsidiary in Gurugram.

In August 2025, SHRM discovered that Strategic HRM, an Indian entity, was offering HR consultancy and related business services similar to those offered by the plaintiff. It was alleged that the defendant had adopted the domain name www.shrm.in , closely resembling SHRM’s official global domain www.shrm.org . The plaintiff contended that such adoption was dishonest and calculated to misappropriate its goodwill and brand equity built over more than seven decades.

SHRM further alleged that Strategic HRM had reproduced proprietary content from its official website, including an artistic “pie chart” representing its competency model, thereby infringing its copyright as well.

Procedural Background

Aggrieved by the alleged infringement and passing off, SHRM instituted the present suit seeking urgent ex-parte interim relief. The matter came up before Justice Tushar Rao Gedela for consideration of interim injunction.

The plaintiff contended that the defendant’s actions were likely to cause confusion among consumers and members of the public, particularly given the identical field of services and the similarity of domain names.

Issues

1. Whether the plaintiff established a prima facie case of trademark infringement and passing off.

2. Whether the defendant’s use of the mark “SHRM” and the domain www.shrm.in was deceptively similar and likely to cause confusion.

3. Whether ex-parte ad-interim injunction was warranted to prevent irreparable injury.

Contentions of the Parties

The plaintiff submitted that it is the registered proprietor of the “SHRM” mark and enjoys global goodwill and recognition in the HR domain. It was argued that the defendant’s adoption of the identical acronym and similar domain name was dishonest and intended to ride upon the plaintiff’s established reputation.

The plaintiff further contended that the defendant had not only copied the name but had also reproduced proprietary artistic content from its website. Such conduct, it was submitted, constituted infringement of both trademark and copyright, and would lead to deception and confusion among clients and HR professionals.

Reasoning and Analysis

The Court observed that a prima facie case of infringement was clearly made out. Justice Gedela noted that if the defendants were not restrained from continuing the infringing activities, it would lead to confusion and deception among customers and the general public.

Given the similarity of the services offered and the near-identical domain name, the Court held that the likelihood of confusion was evident. The balance of convenience was found to lie in favour of the plaintiff, particularly considering the global reputation and goodwill associated with the SHRM mark.

The Court further observed that failure to grant interim relief would result in irreparable loss and injury to the plaintiff, which could not be adequately compensated by damages.

Decision

The Court passed the following ex-parte ad-interim directions:

• The defendants are restrained from using the “SHRM” trademark, logo or any deceptively similar mark in any manner whatsoever.
• Domain registrars, including Go Daddy India, and web hosts such as Hostgator.com, are directed to block and restrain the infringing website www.shrm.in.

The defendants are directed to suspend or transfer any social media handles infringing upon the plaintiff’s registered trademarks or copyrighted material. Strategic HRM is directed to submit a true and complete statement of accounts of profits to the Court within two weeks.

The matter was listed before the Joint Registrar on 23 April 2026 and before the Court on 7 August 2026 for further proceedings.

In this case SHRM was represented by Mr. Neeraj Bhardwaj, Mr. Mohan Dewan, Mr. N.K. Bhardwaj, Mr. Bikash Ghorai, Mr. Salil Oberoi and Mr. Rahul Maratha, Advocates.