Pluralization and minor graphic variations do not distinguish a trademark from a phonetically and visually similar dominant mark.

The Appellant, owner of the job portal "naukri.com," adopted the trademark "NAUKRI" in 1997 and secured various registrations in Classes 35 and 42 for the word mark and a distinctive "man" device.

The mark was previously recognized by the Delhi High Court as having acquired a secondary meaning and being well-known.

Respondent No. 1 applied for the registration of the mark "naukriyan" (carrying a tagline and a walking man device) in Class 35 on a "proposed to be used" basis in 2023.

The Appellant filed an opposition (No. 1303503), which the Registrar of Trade Marks dismissed on March 25, 2025, holding that the marks were visually and phonetically different.

The Appellant challenged this dismissal and the subsequent issuance of the registration certificate.

The Court applied Section 11 of the Trade Marks Act, 1999, which prohibits registration of marks similar to earlier trademarks for similar services if there is a likelihood of confusion.

It relied on the "Dominant Mark" principle as harmonized with the "Anti-Dissection Rule" in *South India Beverages Private Limited v. General Mills Marketing Inc.*, which establishes that while a mark must be viewed as a whole, it is permissible to accord greater importance to a dominant element that attracts consumer attention.

Additionally, the court applied the "average consumer" test, assessing whether a person of average intelligence and imperfect recollection would be deceived.

The Court found that the word "NAUKRI" is the essential and dominant feature of both marks, as "naukriyan" is merely the plural form of the Hindi word for "job".

The Court noted the Respondent’s own admission in the counter-statement that the mark is simply the plural of "Naukri," which indicates a lack of *bona fide* adoption.

Regarding the "anti-dissection" rule, the Court reasoned that identifying a dominant element is not antithetical to viewing the mark as a whole; here, the commonality of the word "NAUKRI" and the similar "man" device outweighed the minor stylistic differences cited by the Registrar.

The Court further determined that because both parties provide identical online recruitment services to the same consumer base, the likelihood of "autocorrect" or predictive text errors on digital platforms increases the probability of confusion.

The Court held that the Registrar erred by ignoring prior judicial protections granted to the "NAUKRI" mark.

The appeal was allowed, the Registrar’s order dated March 25, 2025, was quashed, and the registration certificate issued to Respondent No. 1 was cancelled.

The Court directed the Registrar of Trade Marks to rectify the Register by removing the "naukriyan" mark within four weeks.