Delhi High Court Upholds Maruti Suzuki’s “TRANSFORMOTION” Trademark, Dismisses Volkswagen’s Appeal

The Delhi High Court has dismissed an appeal filed by German automobile manufacturer Volkswagen AG challenging the registration of Maruti Suzuki India Limited’s trademark “TRANSFORMOTION.”

The Court held that the rival marks “TRANSFORMOTION” and “4MOTION” are sufficiently distinct and do not create a likelihood of confusion among consumers.

The bench of Justice Manmeet Pritam Singh Arora upheld the decision of the Registrar of Trade Marks, which had earlier rejected Volkswagen’s opposition to the registration of Maruti Suzuki’s mark.

“In the considered opinion of this Court, the impugned mark ‘TRANSFORMOTION’ brings the idea/thought of transformation to one’s mind and the submission of the Respondent No. 2 that it is a wordplay of the dictionary word transformation to convey to its consumer the transition of technology from analogue to digital, for its vehicles, appears reasonable. The thought that, therefore, comes to the mind is transformation or transition of the technology used by Respondent No. 2”, the Court held.

The dispute arose after Maruti Suzuki applied to register the trademark “TRANSFORMOTION” in Class 12 for vehicles and related goods. The application was accepted by the Registrar and subsequently published in the Trade Marks Journal.

Volkswagen opposed the registration, arguing that the mark “TRANSFORMOTION” was deceptively similar to its registered trademark “4MOTION.” According to the German automaker, the dominant portion of Maruti Suzuki’s mark incorporated its own mark and could mislead consumers.

After the Registrar rejected the opposition and permitted the registration of the mark, Volkswagen approached the Delhi High Court challenging that decision.

While examining the dispute, the High Court observed that trademark comparison must be carried out by considering the marks as a whole rather than isolating individual elements.

The Court also took note of the fact that both companies are well-known automobile manufacturers with significant goodwill in the Indian market and sell high-value products that are typically purchased after careful consideration.

“This Court also finds that the Appellant herein is Volkswagen AG, and Respondent No. 2 herein is Maruti Suzuki India Limited; both companies have independent, substantial goodwill in the Indian market and, considering the class of products sold by the parties are cars, which are purchased by consumers after due deliberations, this Court is persuaded to hold that there is no material on record to conclude that the consumers would be confused or misled to purchase the goods of the Respondent No. 2 under mistaken belief that the same actually belongs to the Appellant,” the Court observed.

Volkswagen had argued that its mark “4MOTION” is commonly pronounced as “FORMOTION,” and that Maruti Suzuki’s mark merely added the prefix “TRANS,” which did not sufficiently distinguish the two marks.

The High Court rejected this argument, stating that the overall visual and phonetic impressions created by the two marks are different.

“On a comparison of the Appellant's mark ‘4MOTION’ with Respondent No. 2’s whole mark ‘TRANSFORMOTION’, this Court is satisfied that from a visual overlook, there is no plausible chance of confusion between the two rival marks because they are different from one another,” the Court held.

Justice Arora noted that Volkswagen’s mark begins with the numeral “4,” whereas Maruti Suzuki’s mark begins with the word “TRANS,” which significantly alters both the appearance and pronunciation of the marks.

“The Respondent No. 2’s mark starts with alphabets while the Appellant’s mark starts with a numerical ‘4’, which is a stark difference between the two marks. The prefix ‘TRANS’ in Respondent No. 2’s mark ‘TRANSFORMOTION’, when compared with the prefix ‘4’ in the Appellant's mark ‘4MOTION’, leads to distinct pronunciation which in the considered opinion of this Court, does not lead to any likelihood of confusion in the said marks,” the Court observed.

The Court also accepted Maruti Suzuki’s argument that the word “MOTION” is commonly used within the automobile industry and therefore cannot be monopolized by a single manufacturer.

Another factor considered by the Court was the timeline of use of the competing marks in India.

It noted that Maruti Suzuki began using the mark “TRANSFORMOTION” in 2016 as part of its marketing campaign, whereas Volkswagen introduced the “4MOTION” mark in the Indian market only in 2017.

Given this timeline, the Court observed that consumers in India would not have associated Maruti Suzuki’s campaign with Volkswagen’s mark at the time it was introduced.

Finding no merit in Volkswagen’s objections, the High Court dismissed the appeal and upheld the Registrar’s order allowing the registration of Maruti Suzuki’s “TRANSFORMOTION” trademark.

“…..in view of the finding of this Court, that there is no deceptive similarity in the marks, the plea of likelihood of confusion is without any merits”, the Court said.

Case Title: Volkswagen AG v. The Registrar of Trade Marks and Anr

Bench: Justice Manmeet Pritam Singh Arora

Date of Judgement: 12.03.2026