Westmore · UDRP DecisionKhadilife.com
The Panel ordered transfer of <khadilife.com>. It found the domain confusingly similar to the Complainant’s KHADI trademark because it incorporated KHADI with the additional word “life.” The Respondent failed to rebut the Complainant’s prima facie case concerning rights or legitimate interests, and the domain’s previous use for PPC links, including links competing with the Complainant’s products, was not bona fide. The Panel found bad-faith registration and use based on the reputation of the KHADI mark, the domain’s composition, its prior PPC use, and its current passive holding.
The timeline behind khadilife.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind khadilife.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how prior PPC use and later inactivity can be considered together. The earlier competing PPC links supported both the absence of legitimate interests and bad faith, while the mark’s reputation and the composition of the domain allowed the Panel to find that subsequent passive holding did not cure or displace that bad faith.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Khadi & Village Industries Commission v. Saumya jain, VINYL TUBOS PVT LTD Case No. D2025-5142 1. The Parties The Complainant is Khadi & Village Industries Commission, India, represented by Fidus Law Chambers, India. The Respondent is Saumya jain, VINYL TUBOS PVT LTD, India. 2. The Domain Name and Registrar The disputed domain name <khadilife.com> is registered with Name.com, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 10, 2025. On December 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 11, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (private/unavailable) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 12, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amendment to the Complaint on December 15, 2025. The Center verified that the Complaint together with the amendment to the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on December 16, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 5, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 8, 2026. page 2 The Center appointed Vinod K. Agarwal as the sole Panelist in this matter on January 21, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is a statutory body formed by the Government of India under the Act of Parliament, namely, “Khadi and Village Industries Commission Act, 1956”. The Head Office of the Complainant is in Mumbai (India) and it has six zonal offices in different locations in India, namely, Delhi, Bhopal, Bangalore, Kolkata, Mumbai and Guwahati. The Complainant, in April 1957, took over the work of the former All India Khadi and Village Industries Board. The Complainant plays an important role in the Indian economy as it generates employment in about 2.48 lakh villages throughout the country. The Complainant has a widespread presence across the country and implements its various programs in all the Indian states. Further, the Complainant has offices in 28 states of India for the implementation of its various programmes. Ever since its formation in the year 1956, the Complainant has been carrying on work related to implementation of programs for the development of Khadi and other Village Industries (KVI) in the rural areas in coordination with other agencies. The programmes offered by the Complainant are to promote products under one of its trademarks, namely, KHADI. There are about numerous sales outsets directly owned by the Complainant spread across the country. In its effort to meet the core objectives the Complainant has introduced several interest subsidies schemes for artisans, weavers, and other members of small-scale village and rural industries. The programs offered by the Complainant are to promote products under the trademark KHADI (for example, Indian Trademark Registration No. 2851542, registered on November 27, 2014). The Complainant also implements the Prime Minister’s Employment Generation Program (PMEGP) for the up-liftment and improvement of artisans, weavers, and other members of small-scale village and rural industries. The disputed domain name was registered on May 7, 2024, and previously resolved to an active website, featuring pay-per-click (“PPC”) links. At the time of filing of the Complaint and of drafting this decision, the disputed domain name does not resolve to an active website. 5. Parties’ Contentions According to paragraph 4(a) of the Policy, the Complainant must prove that: (i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) The disputed domain name has been registered and is being used in bad faith. The Complainant contends that each of the three elements specified in paragraph 4(a) of the Policy mentioned above are applicable to the present dispute. Further that the Complainant has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. In relation to element (i), according to the Complaint, it is based on the trademark KHADI registered in favour of the Complainant and used in connection with goods sold and services offered by the Complainant and its authorised members. The Complainant adopted the trademark KHADI (which forms a part of its trade-name, corporate name, and trading style) on September 25, 1956, and the same has been in use continuously till date. By its adoption more than sixty years ago, and extensive use thereof, the trademark KHADI has become exclusively and globally associated with the Complainant in the eyes of consumers. page 3 The Complainant owns numerous registrations of the word mark KHADI. Some of these trademarks are as mentioned below: Trademark Registration Number Class Date of Registration KHADI 2851542 24 November 27, 2014 KHADI 2851543 25 November 27, 2014 KHADI 2851544 26 November 27, 2014 KHADI 2851545 27 November 27, 2014 KHADI 2851546 35 November 27, 2014 It is submitted that the disputed domain name is <khadilife.com> and that the “life” is a generic term. Mere addition of a generic or descriptive or arbitrary term, i.e., “life” with the well-known trademark KHADI of the Complainant, does not serve to distinguish the disputed domain name from the trademark KHADI. Rather, the addition of such term gives an impression that the website hosted on the disputed domain name is used for selling products under the trademark KHADI. Therefore, the presence of the term ‘life’ in no way adds to the distinctiveness of the disputed domain name. It is a settled principle under the Policy that the first element functions primarily as a standing requirement. It is evident that the disputed domain name completely subsumes the Complainant’s trademark KHADI. Accordingly, the essentials of the standing test for confusing similarity have been met. In view of the above, it is submitted that the disputed domain name subsumes the trademark KHADI with a non-distinctive term. As such, the Complainant contends that the requirement of the first element under paragraph 4(a)(i) of the Policy stands satisfied. In relation to element (ii), the Complainant contends the following: The Respondent has parked the disputed domain name and it is not accessible to the public. There is no demonstrable preparation to use or actual use of the disputed domain name in connection with any bona fide offering of goods or services. The landing page of the disputed domain name resolves to a PPC parking page containing links which redirect to third-party search results selling apparel, footwear, among other items, which directly compete with those offered by the Complainant. It is evident that the Respondent seeks to exploit the Complainant’s established reputation and goodwill for commercial gain. In the Complaint, the Complainant has relied on certain earlier decisions under the UDRP. It is stated that in all the cases there was no bona fide use of the disputed domain name by the Respondent for offering goods or services, and the Respondent had merely parked the same to bank on the reputation of the Complainant. Without prejudice to the above, any offering under the disputed domain name will be violating the Complainant’s rights in the trademark KHADI. The Complainant has not authorized or licensed the Respondent to use any of its trademarks in any way. Such unlicensed and unauthorized use of a domain name incorporating the Complainant’s trademark KHADI is solely with a view to misleadingly diverting consumers and to tarnish the trademark of the Complainant. The Complainant has, therefore, established a prima facie case that the Respondent has no rights and legitimate interests in the disputed domain name , and thereby, the burden shifts to the Respondent to produce evidence demonstrating rights or legitimate interests in respect of the disputed domain name. In view of the above, Complainant has satisfied paragraph 4(a)(ii) of the Policy. In relation to element (iii), the Complainant contends the following: The fact that the Respondent has failed to host any content on the disputed domain name or use it for any bona fide offering of goods/services demonstrates that the Respondent has registered the disputed domain name in bad faith and with the mala fide intention to extract some commercial advantage from the Complainant. page 4 The disputed domain name wholly incorporates the trademark KHADI of the Complainant. Thus, the Respondent registered the disputed domain name in bad faith. The fame and unique qualities of the trademark KHADI, which were adopted and applied for by the Complainant well prior to the registration of the disputed domain name, make it extremely unlikely that the Respondent created the disputed domain name independently without any knowledge of the Complainant’s trademark. Moreover, paragraph 2 of the Policy implicitly requires a registrant to make some good faith effort to avoid registering and using a domain name corresponding to trademarks in violation of the Policy. The obligations imposed by paragraph 2 are an integral part of the Policy applicable to all registrants, cannot be ignored. Hence, the Respondent had an onus to ensure that the registration of the disputed domain name did not violate the Complainant’s trademark rights. The disputed domain name does not resolve to an active website at the time of filing. However, it is submitted that the apparent lack of active use (e.g., to resolve to a website) of the domain name does not, as such, prevent a finding of bad faith. Factors that have been considered relevant in applying the passive holding doctrine include: a. the degree of distinctiveness or reputation of the Complainant’s mark; and b. the implausibility of any good faith use to which the domain name may be put. In the present case, the Complainant’s trademark is not only registered in India but has also been declared as a well-known trademark in many other places. Various panels have also acknowledged the well-known nature of the Complainant’s trademark KHADI. Therefore, it is highly unlikely that the Respondent was unaware of the Complainant’s rights in the trademark KHADI, and it is clear that the disputed domain name has been registered by the Respondent solely to benefit from the immense goodwill and reputation associated with the Complainant’s trademark KHADI, and to take advantage of such rights. Accordingly, both elements of the passive holding doctrine are satisfied in the present case. In view of the above submissions, the disputed domain name has been registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 4(a) of the Policy, the Complainant must prove that: (i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) The disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar According to the information submitted by the Complainant, the Complainant is the owner of several KHADI trademark registrations in many jurisdictions. The disputed domain name includes the trademark of the Complainant and therefore, the Panel finds that the disputed domain name is confusingly similar to the trademark of the Complainant. The addition of the word “life” in the disputed domain name does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. Therefore, the Panel finds the first element of the Policy has been established. page 5 B. Rights or Legitimate Interests According to paragraph 4(c) of the Policy, the Respondent may demonstrate its rights to or legitimate interest in the disputed domain name by proving any of the following circumstances: (i) before any notice to the Respondent of the dispute, the Respondent’s use of, or demonstrable preparations to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; or (ii) the Respondent (as an individual, business or other organization) has been commonly known by the disputed domain name, even if the Respondent has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated above. There is no evidence to suggest that the Respondent has become known by the disputed domain name anywhere in the world. The Respondent is known by the name of Saumya jain of VINYL TUBOS PVT LTD. The Complainant has not authorized the Respondent to use the name and their trademark KHADI. It is evident that the Respondent can have no rights or legitimate interests in the disputed domain name as the Respondent has currently made no active use of the disputed domain name, and so has not made a bona fide offering of goods or services, nor a legitimate noncommercial or fair use. The Respondent previously used the disputed domain name for a website, featuring PPC links, some of which compete with the products offered by the Complainant. Such use does not confer any rights or legitimate interests on the Respondent in this case. Further, in view of the fact that the Complainant has not licensed or otherwise permitted the Respondent to use its trademark or to apply for or use the disputed domain name incorporating the trademark of the Complainant and that nobody would use the word “Khadi” unless seeking to create an impression of an association with the Complainant. Based on the evidence in the Complaint, the Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy states that any of the following circumstances, in particular but without limitation, shall be considered evidence of the registration or use of the domain name in bad faith: (i) Circumstances indicating that the Respondent has registered or acquired the disputed domain name primarily for the purpose of selling, renting, or otherwise transferring the disputed domain name registration to the Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of documented out-of-pocket costs directly related to the domain name; or (ii) The Respondent has registered the disputed domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that it has engaged in a pattern of such conduct; or page 6 (iii) The Respondent has registered the disputed domain name primarily for the purpose of disrupting the business of a competitor; or (iv) By using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, internet users to its web site or other on-line location, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s web site or location or of a product or service on its web site or location. The Complainant contends that the disputed domain name was registered or acquired by the Respondent primarily for the purpose of carrying on some of the business competitive to the Complainant. Noting the strong reputation of the Complainant and its trademark, in particular in India, the Panel finds the disputed domain name was likely registered with the intent to deceive the members of the public deliberately and intentionally, with a view to trade upon or en-cash on the name, fame, reputation, image and goodwill acquired by the Complainant. Further, the Respondent previously used the disputed domain name for a website, featuring PPC links, some of which compete with the products offered by the Complainant. This and the other evidence submitted by the Complainant leads to the Panel’s conclusion that the registration and use of the disputed domain name amounts to bad faith. Although the disputed domain name is currently inactive, panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the current passive holding of the disputed domain name does not change the Panel’s finding of the Respondent’s bad faith under the Policy. In addition, in support if its contentions, the Complainant has relied on a number of prior UDRP cases involving the trademark KHADI and which have been decided in their favour. The Panel finds similarities in the present case and the aforesaid decisions. The Panel has taken into the prior decisions into consideration in the preparation of this decision. Considering the above, the Panel finds paragraph 4(a)(iii) of the Policy is satisfied. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <khadilife.com> be transferred to the Complainant. /Vinod K. Agarwal/ Vinod K. Agarwal Sole Panelist Date: February 4, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
What Westmore sees around khadilife.com
The decision is only the record. Westmore connects it to the cases, authorities, panelists, parties and domain evidence surrounding it.

A short, grounded explanation drawn only from this decision's record — not legal advice or a prediction.
Grounded in the Westmore record for this decision. Research/informational only — not legal advice or a prediction of any outcome.
The decision is only the beginning.
You've seen what happened. Now discover the deeper intelligence behind the case, the panelist, the parties and the authorities that matter.
Go beyond the public record: see how this case has been cited, find comparable decisions, analyze the panelist and apply the relevant authorities to your Matter.
Westmore Professional · $395/month
Research with UDRP IntelligenceWestmore AI drafts an attorney-review-ready UDRP response from your facts, grounded in the exact panel and closest precedent.
$895 one-time per matter · no subscription required. Self-help drafting aid — not legal advice.
Build your responseWestmore UDRP records draw on WIPO-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.