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  • Judgements

    DATE: 17/02/2026

    COURT: High Court of Delhi

    BENCH: Justice Manoj Kumar Ohri

    FACTS:

    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 Today and 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.

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