Delhi High Court Restrains Indian Firm From Using 'SHRM' Trademark Of US HR Organisation

Riya Rathore

13 Feb 2026 10:08 AM IST

  • Delhi High Court Restrains Indian Firm From Using SHRM Trademark Of US HR Organisation

    Finding a prima facie case of trademark infringement, the Delhi High Court has barred Strategic HRM from using the “SHRM” mark, observing that failure to grant an ex-parte injunction would cause “irreparable loss and injury” to the US-based Society for Human Resource Management.

    A single-bench of Justice Tushar Rao Gedela passed the order on February 11.

    The Society for Human Resource Management (SHRM) was established in the United States as the American Society for Personnel Administration (ASPA) in 1948, before adopting its current name in 1989. Beyond its status as a professional membership body, the organisation claimed to have played a role in shaping workplace-related legislation and policy in the USA.

    It also claimed to have a global reach with approximately 340,000 members across 180 countries, including a substantial presence in India via its wholly-owned subsidiary in Gurugram.

    In August 2025, the organisation discovered that Strategic HRM was offering HR consultancy and business services nearly identical to its own. It was alleged that the defendant had dishonestly adopted the domain name www.shrm.in, which mirrored SHRM's official global domain, www.shrm.org.

    The organisation alleged that Strategic HRM dishonestly adopted the domain name www.shrm.in to offer services nearly identical to its own. In its pleadings, SHRM contends that the defendant's actions were a calculated attempt to misappropriate the global reputation and brand equity the US entity has built over 75 years.

    It was further claimed by the organisation that the defendant not only copied its name but also reproduced their proprietary content, specifically an artistic 'pie chart' representing a competency model, allegedly copied from the official SHRM website

    Justice Tushar Rao Gedela found that a prima facie case of infringement was evident. The court noted that “if the defendants are not restrained from continuing with the infringement, it would lead to confusion and deception amongst the customers and general public.”

    The High Court ordered the following:

    • The defendants are barred from using the SHRM trademark, logo, or any deceptively similar marks in any manner.
    • Domain registrars like Go Daddy India and web hosts such as Hostgator.com have been directed to block and restrain the infringing website, www.shrm.in.
    • The defendants must suspend or transfer any social media handles that infringe upon the plaintiff's registered trademarks or copyrighted materials.
    • Strategic HRM is directed to submit a true and complete statement of accounts of profits to the court within two weeks.

    The matter is scheduled for further proceedings before the Joint Registrar on April 23, 2026, and will return to the Court on August 7, 2026.

    For SHRM: Advocates Neeraj Bhardwaj, Mohan Dewan, N.K. Bhardwaj, Bikash Ghorai, Salil Oberoi and Rahul Maratha

    Case Title :  Society For Human Resource Management SHRM v. Strategic HRM & Ors.Case Number :  CS(COMM) 128/2026, I.A. 3790/2026, I.A. 3791/2026 & I.A. 3792/2026CITATION :  2026 LLBiz HC (DEL) 142
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