Delhi High Court: In an application filed by the plaintiffs, Toprankers Edtech Solutions (P) Ltd., under Order 39 Rules 1 and 2, Civil procedure Code, 1908 (CPC), seeking ex-parte ad-interim injunction against the defendants, LPT Edtech (P) Ltd., who had launched blatant and malicious campaign plaintiffs thereby tarnishing their goodwill and reputation, the Single-Judge Bench of Tushar Rao Gedela, J., held that the plaintiffs had made out a case for grant of interim injunction and issued following directions to preserve the plaintiffs’ rights pending adjudication of the suit:
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Defendants were restrained from publishing or hosting defamatory and infringing content across all platforms, including the impugned YouTube video.
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They were restrained from using Plaintiff 3’s name, image, or AI-generated content.
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They were prohibited from creating or disseminating any disparaging material targeting the plaintiffs or their trademark.
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They were directed not to tamper with relevant digital or documentary evidence.
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Intermediaries (Google and Meta) were directed to remove or block access to such content within 72 hours.
Factual Matrix
Plaintiff 1 is an established edtech company engaged in coaching and test preparation services under brands such as “Toprankers”, “LegalEdge”, “Creative Edge”, “Judiciary Gold” and “SuperGrads”. Plaintiff 2 is its franchisee operating prominently in Delhi. Plaintiff 3 is a minor student who secured All India Rank 1 in CLAT 2026.
The plaintiffs claimed significant commercial presence, including thousands of enrolled students and substantial revenue generation, particularly in Delhi-NCR. It was claimed that Plaintiff 3 applied for and was selected for a special batch of meritorious students called “CLAT 2026 | Champions Batch I” in February 2025. Plaintiff 3 stated that she had limited interaction with Defendant 1 through certain mock tests under its package “CLAT DLP (Distance Learning Program) 2026”.
After Plaintiff 3 secured AIR 1 in CLAT 2026, a reaction video of her result was recorded and shared by Plaintiff 1, gaining wide publicity across platforms including major media outlets.
The plaintiffs alleged that Defendant 1 attempted to portray Plaintiff 3 as its student and even offered to sponsor her entire college fees in exchange for exclusive promotional rights, which was refused. Despite this, the defendants allegedly began using her name and morphed images to claim credit for her success.
The plaintiffs contended that the defendants launched a coordinated defamatory campaign across platforms including YouTube, blogs, LinkedIn, and Instagram. The content included a video titled “CLAT 2026 AIR 1 Geetali Gupta Controversy Exposed” and multiple posts alleging fraud, deceit, and unethical practices by the plaintiffs. Further, it was alleged that AI-generated and morphed images were circulated portraying the plaintiffs as being behind bars, despite no such arrest having taken place. The plaintiffs also pointed to social media posts and news publications with headlines such as “FIR filed against Toprankers,” alongside visual depictions reinforcing the defamatory narrative.
After Plaintiff 1 issued cease-and-desist notice dated 5 January 2026 requesting to take down the defamatory content, the defendants allegedly filed a false and frivolous FIR in Jodhpur against the plaintiffs and Plaintiff 3’s family. Despite a stay of the FIR by the Rajasthan High Court, the defendants continued publishing defamatory material.
Plaintiffs claimed that with respect to Plaintiff 3, the defendans had committed the following unlawful acts:
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creation and circulation of AI-generated deepfakes,
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morphed content showing endorsement of defendants,
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use of her likeness in datasets and AI tools,
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dissemination of manipulated images.
Further, Plaintiff 2 asserted rights over the registered trademark “LegalEdge” under Class 41, used since 2011 for educational services and contended that the defendants’ use of the mark in disparaging content constitutes trademark infringement.
Issue for Determination
Whether the plaintiffs had made out a case for grant of an ex parte ad-interim injunction against the defendants for defamation and disparagement, trademark infringement, misuse of identity and content relating to Plaintiff 3?
Analysis
At the outset, the Court found that the content of blogs, posts, and videos was prima facie disparaging and appeared to be an attempt to “bring to disrepute the goodwill and reputation” of the plaintiffs. While acknowledging the dispute as arising out of “acrimonious professional rivalry,” the Court held that such conduct cannot be countenanced.
The Court declined to rely on the FIR, noting that it was already under consideration and stayed by the Rajasthan High Court.
Upon examining the substance of the impugned publications, the Court noted that the defendants had openly referred to Plaintiff 1 and also to Plaintiff 3 as being part of an “evil design”, a portrayal which did not appear justified at this stage. It viewed the references to Plaintiff 3, including the circulation of AI-generated or morphed images associating her with the defendants, as unjustified. The Court stated that the unauthorised use of the plaintiffs’ trade marks in posts and video content, coupled with messaging that portrayed the plaintiffs’ services as inferior or substandard, prima facie amounted to disparagement as well as infringement.
With respect to Plaintiff 3, the Court observed that she had been drawn into a “turf war” between the rival institutions as a “bait”, even though she had no real stake in the commercial rivalry. It held the defendants’ conduct in continuing to use her name despite her explicit disassociation to be unjustified. Although it was argued that the cause of action is common to all the 3 plaintiffs, however, the Court was not convinced that Plaintiff 3 would have anything in common between the plaintiffs or the defendants, as her situation appeared to be that of a pawn.
Regarding the misuse of Plaintiff 3’s personality rights, the Court held that a single achievement, such as securing a top rank, does not automatically confer enforceable personality rights. It cautioned against expanding such rights, for any and every success, or a milestone achieved stories, noting that such an approach would lead to “absurdity and incongruity.” It reasoned that if a single academic achievement were sufficient, then every student or aspirant securing a top rank would claim similar protection, which is neither legally sustainable nor desirable.
Decision and Directions
The Court held that the defendants had prima facie conducted a defamatory and disparaging campaign; unauthorised use of the plaintiffs’ trademark “LegalEdge” amounted to infringement; the content was intended to harm reputation and goodwill and thus, interim protection was necessary to prevent irreparable harm.
The Court granted interim injunction in favour of plaintiffs and issued the following directions:
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Defendants were restrained from publishing, hosting, or disseminating any defamatory or infringing content, including the specific impugned video and related posts across all platforms, including the impugned YouTube video.
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They were restrained from using the name, image, or likeness of Plaintiff 3, including any AI-generated or manipulated content.
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They were prohibited from creating or circulating any material that is disparaging, derogatory, or infringing, particularly content targeting the plaintiff’s registered mark “LegalEdge”.
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They were directed not delete, alter, or tamper with any data, records, or digital content forming part of the impugned campaign..
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Intermediaries, such as Google and Meta were directed to remove or block access to such content within 72 hours.
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Notice was issued and defendants were directed to file a written statement within 30 days, along with affidavit of admission/denial.
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Plaintiffs were granted liberty to file replication.
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The matter was listed for further proceedings before the Court on 24 August 2026.
[Toprankers Edtech Solutions (P) Ltd. v. LPT Edtech (P) Ltd., CS(COMM) 344/2026, decided on 13-4-2026]
Advocates who appeared in this case:
Mr. J. Sai Deepak, Senior Advocate with Mr. Ankur Khandelwal, Mr. Chirag Sharma, Mr. Nikhil Saurabh and Mr. Sidhhi, Adv., Counsel for the Plaintifs