Rules 80 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 80 and 81 complete Chapter VII. Rule 80 says what the Registrar does if he has objections to an application for additional protection and how the applicant can obtain his reasons. Rule 81 says what is entered in the register when additional protection is allowed.
If the Registrar has objections, or proposes to accept the application on conditions, he must communicate them in writing. His decision, after a hearing or without one if the applicant has stated in writing that no hearing is wanted, is communicated in writing. An applicant who intends to appeal may, within two months of that communication, ask the Registrar to state the grounds and material he used. If allowed, the Registrar enters a summary of the grounds and material in the register, and the Part A entry carries the date of the application and the proprietor's details.
Where these rules sit
Rules 77 to 79 cover the application on Form GI-9, the joint application by the proprietor and the Part B authorised users, and the Registrar's examination of measurable attributes and global reputation; see our article on rules 77 to 79. The section behind the chapter is section 22(2); see our article on section 22 of the GI Act.
When objections arise, a registered proprietor will often seek legal consultation before replying, because a reply in writing may also be the only hearing the applicant gets.
Rule 80(1): objections and proposals
"If on consideration of the application or any other matter which the applicant may or may be required to furnish, the Registrar has any objections to the acceptance of the application or proposes to accept it subject to such conditions, as he may think right to impose, the Registrar shall communicate such objections or proposals in writing to the applicant."
Two cases are covered:
- the Registrar has objections to acceptance; and
- the Registrar proposes to accept the application on conditions.
In both, the communication must be in writing and must go to the applicant. The heading of rule 80(1) is "Hearing before refusing an application", but the sub-rule text only requires written communication; the hearing is dealt with in sub-rule (2). The text does not give a period for the applicant to respond or for the hearing.
Rule 80(2): decision, and the request for grounds
"The decision of the Registrar under sub-rule (1) after a hearing or without a hearing if the applicant has duly communicated his observations in writing and has stated that he does not desire to be heard shall be communicated to the applicant in writing."
So there are two routes to a decision: after a hearing, or without one if the applicant has sent written observations and has stated that he does not wish to be heard. If the applicant sends nothing and does not appear, the rule does not say what follows.
Then: "if the applicant intends to appeal from such decisions, he may within two months from the date of such communication request the Registrar requiring him to state in writing the grounds and the material used by him in arriving at his decision."
| Step | Who | Period |
|---|---|---|
| Written objections or conditional proposals | Registrar | No period stated |
| Hearing, or written observations with a statement that no hearing is wanted | Applicant | No period stated |
| Written communication of decision | Registrar | No period stated |
| Request for grounds and material, if an appeal is intended | Applicant | Within two months of the communication |
An appeal from the Registrar's decision lies to the High Court under section 31; our article on appeals to the High Court explains it. The two-month request in rule 80(2) is not the appeal itself; it is a request for the Registrar's reasons.
A flag on the numbering
Rule 80 has two sub-rules. Entry 6B of the First Schedule as substituted in November 2025 cites "rule 67 and 80(4)", but there is no sub-rule (4) of rule 80. We flag the reference and do not correct it. Entry 6B concerns an application for leave to intervene in rectification proceedings; see our article on rules 67 and 68.
Rule 81(1): the entry of grounds and material
"Where the Registrar decides to allow the geographical indication in respect of which additional protection is to be provided as envisaged under sub-section (2) of Section 22, he shall enter in the Register a summary of the grounds and the material used by him in arriving at his decision to accord additional protection to the notified goods in respect of the relevant geographical indication application."
This is a transparency duty. The register is to show why additional protection was granted. A third party reading the register learns the grounds and material, not just the result. The rule asks for a "summary", and it does not say how long it must be or where in Part A it sits beyond the next sub-rule.
Rule 81(2): what the Part A entry states
"The entry in Part A of the Register shall state the date on which the application for additional protection was made, the name, description and principal place of business in India of the registered proprietor and if they do not carry on business in India their address for service in India."
| Particular | Required entry |
|---|---|
| Date | The date on which the application for additional protection was made |
| Proprietor | Name, description and principal place of business in India |
| If no business in India | Address for service in India |
Part A of the register is the part for the geographical indication and its proprietor; see our article on Part A and Part B of the register. Note that the entry states the date of the application, not the date of the decision. The rules do not say what legal effect that date has.
Who is affected
- Registered proprietors who have applied under rule 77, who must answer objections and decide whether to appeal.
- Authorised users in Part B, who joined the application under rule 78 and are bound by the outcome.
- Third parties, including traders using "style" or "type" wording, who can read the grounds in the register.
An example
Tamralipta Pearl Growers' Federation applied for additional protection for its registered indication. The Registrar writes that he proposes to accept the application only if the Federation gives a definition of the production area. The Federation sends written observations stating it does not want a hearing. The Registrar then refuses part of the claim and communicates his decision in writing. The Federation, intending to appeal, writes to the Registrar within two months for the grounds and material he used. Had additional protection been allowed, rule 81 would require a summary of the grounds to be entered in the register, and the Part A entry to show the date of the Federation's application and its address.
Silences
The text does not fix a period for the Registrar's decision, does not say what form the Registrar's grounds must take, and does not say whether the two-month request pauses the period for an appeal under the Act.
Amendments made after November 2025 should be checked before acting.
Need help with an additional protection decision?
If the Registrar has raised objections, the reply and the two-month request for grounds are both time-sensitive. Our legal consultation team can read the Registrar's letter, prepare observations and advise on the next step.
Key takeaways
- The Registrar must communicate objections or conditional proposals in writing.
- The decision is communicated in writing, after a hearing or after written observations with no hearing wanted.
- An applicant who intends to appeal may ask within two months for the grounds and material.
- If allowed, a summary of grounds and material is entered in the register.
- The Part A entry shows the application date and the proprietor's name, description and address.
- Entry 6B refers to "rule 80(4)", which does not exist.
Read next
- Rules 77 to 79: additional protection application and consideration
- Rules 74 to 76: trade marks conflicting with a geographical indication
- Section 22 of the GI Act: infringement of registered geographical indications
- Section 7 of the GI Act: Part A and Part B of the register
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.
