Howard Auto-Cultivators Limited v Webb Industries Pty Ltd [1946] HCA 15

Howard Auto-Cultivators Limited v Webb Industries Pty Ltd [1946] HCA 15

The majority (Rich, Starke, Dixon, McTiernan JJ; Latham CJ, Williams J dissenting) held that 'Rohoe' was not an invented word under s. 16(1)(c) of the Trade Marks Act 1905-1936 because it was a transparent contraction of the commonly known words 'rotary' and 'hoe', thus registration should be refused.

Parties
Appellant/opponent: Howard Auto-Cultivators Limited; Respondent/applicant: Webb Industries Proprietary Limited
Jurisdiction
Australia
Procedural Posture
Appeal From Deputy Registrar of Trade Marks / Judgment on Appeal
Outcome
Appeal allowed; application for registration refused
Legal Topics
Trade Marks, Invented Words, Registrability of Trade Marks

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 13 Party arguments 2
Sign in to unlock

Parties

Howard Auto-Cultivators Limited

Appellant/opponent

Webb Industries Proprietary Limited

Respondent/applicant

Procedural Posture

Appeal From Deputy Registrar of Trade Marks / Judgment on Appeal

  1. 1 Whether the word 'Rohoe' is an invented word within the meaning of s. 16(1)(c) of the Trade Marks Act 1905-1936 and thus registrable as a trade mark in respect of cultivating implements

Ratio Decidendi

The majority (Rich, Starke, Dixon, McTiernan JJ; Latham CJ, Williams J dissenting) held that 'Rohoe' was not an invented word under s. 16(1)(c) of the Trade Marks Act 1905-1936 because it was a transparent contraction of the commonly known words 'rotary' and 'hoe', thus registration should be refused.

Court Disposition

Appeal allowed; application for registration refused

Orders

  • Order of Deputy Registrar set aside
  • Application for registration refused