Delhi High Court: In an application filed by Isha Foundation (plaintiff) under Section 151, Civil Procedure Code, 1908, seeking modification/clarification of its earlier interim order dated 19 March 2026, wherein the Court had restrained Google LLC (Defendant 1), Nakkheeran Publications (Defendant 2), and Publisher and Editor of Defendant 2 (Defendant 3) from publishing or disseminating allegedly defamatory content concerning the Foundation and directed intermediaries to remove the impugned videos and articles identified in the injunction application, a Single Judge Bench of Subramonium Prasad, J., held that where the omitted material already forms part of the original pleadings and the relief initially sought, its express inclusion in the operative directions amounts to a permissible modification to give effect to the Court’s original intent, and not a review or expansion of the earlier order.
Accordingly, the Court modified its interim order to expressly direct the removal of an additional 39 short videos and 5 English-language videos referred to in the plaint, holding that no separate adjudication was required as the impugned content had already been brought within the scope of the original proceedings.
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Background
The dispute arises from a defamation suit instituted by Isha Foundation against Google LLC, Nakkheeran Publications, and others, alleging that the defendants had created, uploaded, published, and circulated ex facie false, malicious, and per se defamatory content targeting the Foundation, its founder, and its followers.
According to the plaint, the impugned content was disseminated through the “Nakkheeran TV” YouTube channel, operated by Defendants 2 and 3, and was also uploaded in English on another YouTube channel, “Nakkheeran Neo”. The Foundation contended that these videos were further hosted on Defendant 3’s website, resulting in widespread circulation.
The plaintiff asserted that the gravamen of the suit centred on 11 videos which, according to it, had garnered significant public attention, generated substantial revenue for Defendants 2 and 3, and caused serious reputational harm by maligning the image of the Foundation, its founder, and its followers.
On 19 March 2026, the Delhi High Court granted an interim injunction restraining the defendants from creating, publishing, uploading, sharing, or disseminating any defamatory content concerning the plaintiff and directed the removal of the impugned videos and articles identified in the injunction application.
Subsequently, the plaintiff filed the present application under Section 151, Civil Procedure Code, 1908, seeking modification of the interim order to expressly include 39 short videos and 5 English-language videos mentioned in Para 10 of the plaint, contending that these videos formed part of the original cause of action and contained substantially identical defamatory content.
Analysis and Decision
The Court observed that although the application had been styled as one seeking clarification, it was in effect an application for modification.
However, the Court held that the modification did not introduce a new or independent relief. The Court noted that Para 25 of the earlier interim injunction application expressly incorporated the contents of the plaint, including Para 10, making those pleadings part of the application itself.
The Court further observed that its earlier order had already relied upon Para 25 of the injunction application while holding the impugned content to be prima facie defamatory. Since the additional 39 short videos and 5 English-language videos were already part of the pleadings and allegedly contained substantially identical content, they did not require fresh adjudication.
Accordingly, the Court held that modification of the earlier order was necessary to give full effect to its original intention and ensure complete implementation of the interim injunction.
Allowing the application, the Court modified Paras 58 and 59 of its order dated 19 March 2026 and directed that, in addition to the previously identified content, the 39 short videos and 5 English-language videos referred to in Para 10 of the plaint shall also be removed.
The Court directed that this order shall be read conjointly with the order dated 19 March 2026 and that whenever a certified copy of the earlier order is issued, a copy of the present order shall also accompany it.
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[Isha Foundation v. Google LLC, I.A. 11822/2026 in CS(OS) 957/2024, decided on 28-7-2026]
Advocates who appeared in this case:
For the Plaintiff: Mr. Rahul Sagar Sahay, assisted by the Athena Legal team comprising Mr. Simranjeet Singh, Partner, along with Mr. Rishabh Pant and Mr. Abhijeet Pandey, Associates; Mr. Pratham Arora, Advocate
For Defendant No. 1: Mr. Aditya Gupta and Ms. Vani Kaushik, Advocates.
For Defendants No. 2 and 3: Ms. K. Vaijayanthi, Dr. Ram Sankar and Mr. Nagender, Advocates.