Rules 65 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rules 65 and 66 set out how a person who wants an entry on the Register of Geographical Indications cancelled, expunged or varied makes the application, and how the registered proprietor answers it. They implement section 27 of the Act.
An application under section 27 is made in triplicate on Form GI-6 or Form GI-5, with a statement in triplicate giving the applicant's interest, the facts and the relief sought. The Registrar sends copies to the proprietor and interested persons within two months. The proprietor files a counterstatement on Form GI-2 within two months (extendable to not more than two months in all), and rules 44 to 51 then apply.
What rule 65 covers
Rule 65 deals with "an application to the Registrar under Section 27 for the cancelling, expunging or varying of any entry relating to a geographical indication or of the Statement of Case referred to under rule 32(1) recorded in the Register ... or an authorised user in the register". In plain terms there are three targets: an entry for a geographical indication, the statement of case recorded in the register, and the entry of an authorised user. The section behind it is explained in our article on section 27 of the GI Act.
Forms, copies and the statement
The application is "made in triplicate on Form GI-6 or Form GI-5, as the case may be". The Rules give the choice by purpose:
| Purpose | Form | Fee entry (First Schedule as substituted in November 2025) |
|---|---|---|
| Rectification of the register or removal of a geographical indication, or expunging or varying the statement of case, or removal of an authorised user (entry 6A) | Form GI-6 | 6A, Rs. 1,000 |
| Rectification of the register in Part B for the removal of an authorised user (entry 5D) | Form GI-5 | 5D, Rs. 1,000 |
The rule does not itself say which of the two entries applies where an authorised user is the target; entry 6A mentions the removal of "an authorised user from the Register" and entry 5D mentions the removal of an authorised user from Part B. Check the form and entry with the Registry when the target is an authorised user.
The application must be accompanied by "a statement in triplicate setting out fully the nature of the applicant's interest, the facts upon which he bases his case and the relief which he seeks". An applicant who cannot show a genuine interest, or who leaves out the relief sought, has not complied with the rule.
Because the filing must set out the whole case at the start, many applicants take advice from a legal dispute resolution practitioner before filing.
Where the applicant is not the proprietor
Where the applicant "is not the registered proprietor", the application and statement "shall be left at the Geographical Indications Registry in triplicate". If there are authorised users, the filing must carry either:
- as many extra copies as there are authorised users on the register, or
- proof of publication in leading national newspapers circulated widely in the definite territory, region or locality to which the geographical indication relates, notifying the general public of the proposed application for rectification or removal with full particulars.
This second route matters for a challenge to a geographical indication with many users, such as a handloom area, where printing dozens of copies would be impractical.
What the Registrar does, and verification
"A copy each of the application and statement shall be transmitted within two months by the Registrar to the registered proprietor and to any other person who appears from the register to have an interest in the geographical indication or makes a request for the same." The application must be verified "in the manner prescribed under Rule 42 for verification of notice of opposition". Rule 42 requires the verification to say, by reference to numbered paragraphs, what is verified of the maker's own knowledge and what on information received and believed to be true, and to be signed with date and place. For the same practice in opposition, see our article on opposition to registration under section 14.
Rule 66: the counterstatement
Once the registered proprietor receives the copy from the Registrar, rule 66 gives "two months or ... such further period not exceeding two months in the aggregate" to send, to the Registrar and to the applicant, a counterstatement "in triplicate" on Form GI-2 giving "the grounds on which the application is contested". Entry 2B of the First Schedule covers a counter-statement "in answer to an application under section 27 in respect of each geographical indication", Rs. 1,000, as per the First Schedule as substituted in November 2025.
The Registrar "shall serve a copy of the counterstatement on the person making the application within one month of the receipt of the same". After that, "the provisions of rules 44 to 51 shall ... apply mutatis mutandis to the further proceedings". Those rules govern evidence by affidavit, exhibits, translations, hearing and decision, and costs in the opposition setting; read them with this rule.
Failure to file a counterstatement
Rule 66 contains a protection that is easy to miss. The Registrar "shall not ... rectify the register or remove the geographical indication or any authorised user from the register merely because the registered proprietor or the authorised user has not filed a counterstatement unless he is satisfied that the delay in filing the counterstatement is wilful and is not justified by the circumstance of the case". Silence is not an admission. Even so, no proprietor should rely on this; a missed deadline invites a finding of wilful delay. The rule ends: "In any case of doubt any party may apply to the Registrar for directions."
Timeline at a glance
| Step | Who | Period |
|---|---|---|
| File application and statement, triplicate, verified | Applicant | No period stated in the rule |
| Copies sent to proprietor and interested persons | Registrar | Within two months |
| Counterstatement on Form GI-2 | Registered proprietor | Two months, extendable to not more than two months in the aggregate |
| Copy of counterstatement served on applicant | Registrar | Within one month of receipt |
| Evidence, hearing, decision | Parties and Registrar | Rules 44 to 51 apply |
An example
Meghdoot Spice Traders believe that a registered geographical indication for a saffron variety includes a grower area outside the traditional zone. They file Form GI-6 in triplicate with a statement of their interest as buyers, the facts and the relief sought (variation of the statement of case). As the register shows 40 authorised users, they publish a notice in two widely circulated newspapers and file proof of it. The Registry sends the papers to the proprietor within two months; the proprietor has two months to answer on Form GI-2. If the proprietor is silent, the Registrar still needs to be satisfied the delay was wilful before acting on that alone.
Points to note
- The rule gives no period within which the applicant must file; limits may sit elsewhere in the Act.
- Appeals from the Registrar's decision lie to the High Court under section 31 (see our article on appeals to the High Court); rectification can also be sought before the High Court, covered in the article on sections 34 and 35.
Amendments made after November 2025 should be checked before acting.
Need help with a rectification dispute?
Whether you want to remove an entry or defend one, the first filing sets the case. Our legal dispute resolution team can prepare the Form GI-6 and statement, or the Form GI-2 counterstatement, and track the two-month periods for you.
Key takeaways
- Rule 65 applies to section 27 applications to cancel, expunge or vary an entry, the statement of case, or an authorised user.
- File in triplicate on Form GI-6 or Form GI-5 with a statement of interest, facts and relief.
- A non-proprietor applicant must supply copies for every authorised user or proof of newspaper publication.
- The Registrar forwards copies within two months; the proprietor has two months (not more than two months extension) for Form GI-2.
- Rules 44 to 51 govern what follows.
- Failure to counter alone is not a ground for removal unless the delay is wilful and unjustified.
Read next
- Rules 67 and 68: intervention and rectification of the register by the Registrar
- Rules 62 to 64: removal, restoration and renewal
- Section 27 of the GI Act: power to cancel or vary registration
- Rules 97 and 98 of the Trade Marks Rules, 2017: rectification of a trademark
Disclaimer: Based on the Geographical Indications of Goods (Registration and Protection) Rules, 2002 as notified on 8 March 2002 and as amended by the Amendment Rules of 2020 (G.S.R. 528(E)) and 2025 (G.S.R. 812(E)), as consulted on 2 October 2026. Later amendment rules, forms and fees should be checked in their current form. This article is general information, not legal advice; check the official text before acting.