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Legal Reasoning

The court applied the settled principles governing the grant of an ad‑interim injunction in defamation suits. It held that the plaintiffs must establish a prima facie case, show that the balance of convenience favours them, and demonstrate that they would suffer irreparable injury if the injunction were not granted. The judge found all three requirements satisfied.

Regarding the prima facie case, the judge pointed to the explicit allegations in the reels that impute criminal conduct and moral turpitude to the plaintiffs without any substantiating evidence. The judge concluded that the content is prima facie defamatory.

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On the balance of convenience, the judge noted that the defendant’s freedom to post content on social media is not absolute and must yield when such content is alleged to be false and harmful. The judge observed that the defendant could continue to express opinions on other subjects, but the specific reels in question are not protected speech insofar as they are based on false statements of fact.

The judge also considered the public interest in preventing the spread of misinformation that could damage personal reputation, especially when the content has already gone viral.

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Operative Outcome

Accordingly, Judge Bukke issued an order directing the defendant, her agents, representatives and any persons acting on her behalf to:

Remove forthwith the two impugned Instagram reels identified as Exhibits B, C, D and E from all social media platforms and any other medium;
Refrain from publishing, posting or circulating any defamatory or scandalous content against the plaintiffs or their companies until the next date of hearing;
Comply with the notice issued to the defendant and to unknown John Doe defendants requiring them to take down the alleged defamatory material.

The order is operative until the matter is heard again, at which time the court will consider whether to make the injunction permanent or to modify its terms.

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Implications

The decision underscores the willingness of Indian courts to intervene swiftly in cases where social media content is alleged to be defamatory and to have achieved wide dissemination. It signals that influencers with large followings are not exempt from the ordinary rules governing defamation, and that courts may grant interim relief to protect reputation even before a full trial on the merits.

For the plaintiffs, the order provides immediate relief by curbing further circulation of the contested reels and obligating the defendant to delete the existing posts. For the defendant, the order imposes a temporary restraint on specific content while leaving open the possibility to contest the claims at a later stage.

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The case also highlights the procedural mechanism whereby plaintiffs can seek notice to unknown parties (John Doe defendants) to ensure that any reposts or mirrors of the offending content are addressed, reflecting an adaptive approach to the challenges posed by viral social media sharing.