The present matter arose from two civil
suits filed by certain respondent universities before the Court of the learned
ADJ-01, South West District, Dwarka Courts, New Delhi. In these suits, the
respondents sought permanent and mandatory injunctions restraining the
appellant, an EdTech-based startup operating the website www.getmyuni.com,
from using, displaying, or publishing the names, information, and details of
the respondent universities on its platform. By orders dated 28 March 2023, the
Trial Court allowed applications under Order XXXIX Rules 1 and 2 of the CPC and
restrained the appellant from using such information, further directing
deletion of all details relating to the respondent universities during the
pendency of the suits.
Aggrieved by these interim injunctions, the
appellant preferred the present appeals before the Delhi High Court. The appellant contended that
it merely aggregated and published publicly available information regarding
universities and colleges, including rankings sourced from the National
Institutional Ranking Framework (NIRF) and reputed publications such as India
Todayand The Week.
It was asserted that no misrepresentation, editorial manipulation, or false
association with the respondent universities had been made. The appellant
further submitted that discussions between the parties for a possible
memorandum of understanding relating to lead generation had failed, and that
the suits were filed out of dissatisfaction arising from non-execution of the
MoU rather than any legal infringement.
ISSUES:
The central issue before the Court was
whether the appellant’s use and display of publicly available information and
rankings relating to the respondent universities on its website amounted to a
prima facie case of disparagement, misrepresentation, or infringement
warranting an interim injunction restraining such use during the pendency of
the suits.
JUDGEMENT WITH REASONING:
The Court allowed both appeals and set
aside the interim injunction orders passed by the Trial Court. It held that the
respondents had failed to establish a prima facie case in their favour and that
the appellant was entitled to use publicly available information relating to
the respondent universities, provided such information was not presented in a
disparaging or misleading manner.
The Court carefully examined the material
on record and found no evidence to suggest that the appellant had manipulated
or altered the rankings issued by recognised ranking agencies such as NIRF, or
that it had added any subjective editorial commentary on the quality of the
respondent universities. The information displayed on the appellant’s website
was traceable to open-source material available in the public domain, including
rankings published by established agencies and magazines. The Court noted that
merely presenting such data in an aggregated or comparative format could not,
by itself, be construed as disparaging or defamatory, particularly when the
rankings were transparently referenced to their original sources.
The Court further observed that the
respondents had neither challenged the rankings issued by the ranking bodies
nor exercised any recognised right, such as seeking removal of their listings
from search engines. It also took note of the absence of any allegation that the
appellant had appropriated the intellectual property of the respondents or
falsely claimed affiliation or endorsement. The grievance regarding
hyperlinking to the respondents’ websites was held to be legally untenable in
the absence of misrepresentation. Concluding that the respondents had failed to
demonstrate irreparable harm or a balance of convenience in their favour, the
Court held that the Trial Court erred in granting injunctive relief and
accordingly vacated the impugned orders.
ANALYSIS:
The decision underscores the legal
permissibility of aggregating and disseminating publicly available information
in the digital ecosystem, particularly by intermediary platforms operating in
the education-technology space. The Court adopted a balanced approach by recognising
that rankings and institutional data published by statutory bodies and reputed
private agencies form part of the public domain and may be lawfully reproduced,
compared, or aggregated, provided the presentation remains faithful to the
source and free from editorial distortion. By setting aside the interim
injunctions, the Court reaffirmed that mere dissatisfaction with visibility,
ranking placement, or comparative presentation cannot, by itself, give rise to
a cause of action for disparagement or infringement. The ruling thus provides
important clarity on the threshold required to restrain online platforms at the
interlocutory stage, especially where the information complained of is
open-sourced and transparently attributed.
Equally significant is the Court’s emphasis
on the traditional principles governing the grant of interim injunctions,
namely the existence of a prima facie case, balance of convenience, and
irreparable harm. The respondents’ failure to challenge the underlying
rankings, assert any misuse of intellectual property, or demonstrate false
association proved fatal to their case. The Court also implicitly cautioned
against the use of injunctive proceedings as a tool to exert commercial
pressure following the breakdown of contractual negotiations. By protecting the
appellant’s right to publish neutral, evidence-based information, the Delhi High Court reinforced the principle that
courts must avoid chilling legitimate informational speech and digital
aggregation, particularly when such content serves a broader public interest by
enabling informed decision-making.