The Delhi High Court has temporarily restrained Sphinx Worldbiz Ltd and a company under its control from using the "SHRM PRO" trademark for their services, granting an ex parte ad interim injunction in a trademark infringement suit filed by the Society for Human Resource Management (SHRM).

Justice Vikas Mahajan observed that the use of the mark by the two companies prima facie appeared to be non-bona fide and was causing confusion, deception and a false association among the public. The court noted that consumers could mistakenly believe the services originated from SHRM or were connected with or endorsed by the organization, which offers advocacy, consultancy, business research, professional networking and conferences to human resources professionals.

In a consequential direction, the court also ordered GoDaddy.com LLC, impleaded as the domain registrar and web-hosting provider, to withdraw support for the website shrmpro.com. Apple Inc and Google LLC were directed to block or disable access to the mobile applications "SHRMpro" and "SHRMpro-geo," which are available on their respective platforms. The involvement of the tech giants reflects the reality that trademark disputes increasingly require cooperation from third-party intermediaries to be effective.

A mark applied for within weeks of incorporation

The dispute centres on a company incorporated in September 2021 that operates under Sphinx Worldbiz's control. According to SHRM's case, the entity applied to register "SHRM PRO" on October 14, 2021 — less than a month after its incorporation — and did so on a "proposed to be used" basis.

SHRM opposed that application on June 11, 2024, and it was recorded as abandoned on December 17, 2024, after the company failed to file a counter statement. The company then filed a fresh application for the word mark "SHRMpro" in Class 42 on October 7, 2025, this time claiming use since May 12, 2023.

SHRM sent a cease-and-desist notice on October 30, 2025, but the company refused to comply in its reply the following day. That pattern — the prompt application after incorporation, the abandoned first registration attempt, and the immediate rejection of the cease-and-desist demand — formed a significant part of SHRM's pleadings.

A dormant website and a deceptively similar look

SHRM further alleged that although shrmpro.com was registered in 2015, archived records showed no discernible use of the website until around late 2020. The organization also claimed that the website employs a blue-and-white colour scheme and visual presentation deceptively similar to SHRM's own branding, adding to the risk that the public would draw a false association between the two sets of services.

Taken together, SHRM argued, these factors pointed to an intent to ride on the goodwill of the "SHRM" brand rather than to develop an independent identity in the market. The court accepted that SHRM had established a prima facie case for an ex parte ad interim injunction, that the balance of convenience favoured granting relief, and that SHRM would suffer irreparable loss and injury if the injunction were refused.

Scope of the restraint

Until the next hearing, Sphinx Worldbiz, the company operating under its control, and all those acting on their behalf are restrained from offering for sale, advertising, marketing, exporting, importing, displaying or otherwise dealing in services under "SHRM PRO" or under any mark identical or deceptively similar to SHRM's registered "SHRM," "SHRM INDIA" and other formative trademarks, where such use amounts to infringement or passing off.

The restraint applies to online and offline activity alike, including social media. The breadth of the order matters: it is not confined to the exact "SHRM PRO" mark but extends to marks that are indistinguishable or confusingly similar to SHRM's registered family of marks. That gives SHRM protection beyond the specific website and app names at the centre of the suit.

Because the injunction was granted ex parte, it was issued without hearing the defendants. The order is therefore interim in nature and subject to modification or vacation after the defendants are given an opportunity to contest it. Such orders are granted only where the court is satisfied that the urgency is genuine and that delay would cause irreparable harm.

What happens next

The matter is listed before the Joint Registrar on December 2, 2026, and will next be heard by the court on January 19, 2027. The Registrar's hearing will deal with procedural matters, including the completion of pleadings, before the main arguments on the injunction are taken up. At that stage, the defendants can argue against the continuation of the order, and the court will determine whether the interim arrangement should hold pending the final disposal of the suit.

For SHRM, the order provides immediate, practical relief: the website and apps associated with the disputed mark must be blocked, and the defendants must cease all use of the contested branding until the court decides otherwise. For Sphinx Worldbiz and its controlled entity, the practical consequence is significant — their services, online presence and distribution through app stores are now in limbo pending the next round of proceedings.

The case also illustrates the growing willingness of Indian courts to issue orders that run beyond the parties themselves, requiring online intermediaries such as domain registrars and app store operators to enforce trademark relief. As the digital economy expands, such directions are likely to become an increasingly common feature of infringement litigation.