Rules 72 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.
After a registered proprietor applies under section 29 to add to or alter a registered geographical indication, rules 72 and 73 take over. Rule 72 requires advertisement and gives any person a period to oppose. Rule 73 deals with the decision and the Journal notification.
The Registrar must advertise the alteration application in the Journal before deciding it. Any person may oppose on Form GI-2 within three months of the advertisement (the rule also mentions an extension that may not exceed one month in all). The proprietor answers with a counterstatement within two months, and rules 44 to 51 apply. If there is no opposition the Registrar decides after hearing the applicant if he wishes. If allowed, the register is altered and a notification is inserted in the Journal.
Where these rules fit
Rule 71 and section 29 allow the registered proprietor to apply for leave to add to or alter the indication on Form GI-9, with five copies. We cover them in our article on rules 70 and 71 and on sections 28 to 30 of the GI Act. Rules 72 and 73 supply the next steps, which resemble the opposition procedure for a fresh application.
Rule 72(1): advertisement before decision
"The Registrar shall consider the application and shall, advertise the application in the Journal before deciding it." Two verbs, both "shall": consider, then advertise. Nothing is decided before advertisement. The rule does not set a time for the advertisement.
Because the opposition period starts on the date of the Journal advertisement, watchful producers and traders often engage a legal dispute resolution practitioner to monitor the Journal.
Rule 72(2): who may oppose, when and how
"Within three months from the date of advertisement under sub-rule (1), or within such period not exceeding one month in the aggregate any person may give notice of opposition to the application on Form GI-2 and may also send therewith a statement of his objections."
Three points. First, "any person" may oppose; the rule requires no special interest. Second, the base period is three months from the advertisement. Third, the words "or within such period not exceeding one month in the aggregate" are printed without saying what the period is added to; the sensible reading is a further period of up to one month. The sentence is incomplete as printed, and we flag it rather than complete it. Compare rule 41(5), which lets a person ask for an extension of time for filing a notice of opposition; entry 2C of the First Schedule (Rs. 300) refers to extension of time for opposition under sections 14(1), 17(3)(e) and 29(2).
The notice and statement "shall be sent in triplicate". Where there are authorised users under the registration, the notice and statement "may also be accompanied by as many copies thereof as there are authorised users". A copy "shall be transmitted by the person giving notice to registered proprietor and authorised user if any or alternatively issue a public notice in al least two leading local newspapers circulated widely in the definite territory, region or locality to which the geographical indication relates".
Rule 72(2): the Registrar and the counterstatement
The Registrar "shall forward within two months a copy of the notice and statement to the registered proprietor". The proprietor, "within two months from the receipt ... of such copies from the Registrar", sends to the Registrar on Form GI-2 "a counter-statement in triplicate of the grounds on which the opposition is contested".
If the proprietor files a counterstatement, "the Registrar shall serve a copy thereof on the person giving notice of opposition within one month", and "the provisions of rules 44 to 51 shall thereafter apply mutatis mutandis to the further proceedings on the opposition". Those rules cover evidence in support of opposition, evidence by the applicant, evidence in reply, further evidence, exhibits, translations, and hearing and decision.
Silence by the proprietor does not decide the matter: "The Registrar shall not refuse the application merely because the registered proprietor 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." And "in any case of doubt any party may apply to the Registrar for directions". The same safeguard appears in rule 66 for rectification; see our article on rules 65 and 66.
Fees
As per the First Schedule as substituted in November 2025:
| Step | Entry | Amount |
|---|---|---|
| Counter-statement in answer to a notice of opposition under section 29 | 2B (Form GI-2) | Rs. 1,000 |
| Extension of time for filing notice of opposition (sections 14(1), 17(3)(e), 29(2), rule 41(5)) | 2C (Form GI-2) | Rs. 300 |
| Application for leave to add or alter a registered geographical indication (except by or on behalf of a public authority, or in consequence of a statutory requirement) | 9B (Form GI-9) | Rs. 300 |
Entry 2A (the notice of opposition) refers to opposition under section 14(1) and to an opposition to an authorised user; it does not mention section 29 or rule 72 by name. The text does not say which entry covers a notice of opposition to an alteration, so confirm with the Registry before filing.
Rule 72(3): no opposition
"If there is no opposition, within the time specified in sub-rule (2), the Registrar shall, after hearing the applicant if he so desires allow or refuse the application and shall communicate his decision in writing to the applicant." The Registrar may therefore refuse even an unopposed application; the applicant must be heard if he wishes.
Rule 73: decision, advertisement and notification
"If the Registrar decides to allow the application he shall alter the geographical indication in the register accordingly and insert in the Journal a notification that the geographical indication has been altered. If the application has not been advertised under rule 71, he shall also advertise in the Journal the geographical indications as altered."
Rule 73 refers to advertisement "under rule 71", but the advertisement duty is in rule 72(1); rule 71 deals with the application and service. This looks like a drafting slip. We flag it and do not correct it. The apparent intention is that if the altered indication was not already advertised under rule 72, the altered indication itself must now be advertised.
An example
Banaras Brocade Guild, as registered proprietor, applies under section 29 to add a motif description to its registered indication. The Registrar advertises the application in the Journal. Within three months, Jaipur Textile Traders send a notice of opposition on Form GI-2 in triplicate with copies for the authorised users. The Registrar forwards the papers to the Guild within two months, and the Guild files a counterstatement within two months of receipt. Evidence and hearing follow under rules 44 to 51. If the Registrar allows the alteration, the register is altered and the Journal carries a notification.
What the rules do not say
- No time is fixed for advertisement or for the decision.
- The extra period of "not exceeding one month in the aggregate" is not tied to a start point.
- There is no separate rule on costs here; see our article on rules 89 to 91.
Amendments made after November 2025 should be checked before acting.
Need help with an opposition?
Opposing or defending an alteration depends on dates that start from the advertisement. Our legal dispute resolution team can prepare the Form GI-2 notice or the counterstatement and follow the evidence stages with you.
Key takeaways
- The Registrar advertises the section 29 application in the Journal before deciding.
- Any person may oppose on Form GI-2 within three months of the advertisement, with a possible extension not exceeding one month in all.
- The proprietor's counterstatement is due within two months of receiving the Registrar's copy.
- Rules 44 to 51 govern evidence, exhibits, hearing and decision.
- If unopposed, the Registrar still decides after hearing the applicant if he wishes.
- Rule 73 refers to "rule 71" where rule 72 is meant.
Read next
- Rules 70 and 71: correction of the register and alteration of a registered GI
- Rules 65 and 66: application to rectify or remove
- Sections 28 to 30 of the GI Act
- Section 14 of the GI Act: opposition to registration
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.