Delhi High Court cautions against over-expansive interpretation of personality rights

Delhi High Court cautions against over-expansive interpretation of personality rights

New Delhi, May 5 (IANS) The Delhi High Court has cautioned against an over-expansive interpretation of "personality rights", observing that not every individual achievement or academic success can be elevated to such protection, as it would result in "absurdity and incongruity".

A single-judge Bench of Justice Tushar Rao Gedela made the observation while dealing with a commercial suit arising from a dispute between rival edtech platforms, involving allegations of defamation, disparagement, and unauthorised use of trademarks, as well as the use of a CLAT 2026 topper’s identity.

The Delhi High Court stated that expanding the scope of personality rights to cover every instance of success — such as a student securing a top rank in a competitive examination — would set an unworkable precedent.

"In case any and every success, or a milestone achieved, is held to be sufficient to be raised to the level of a ‘personality right’, it would lead to absurdity and incongruity," Justice Gedela said.

"If such interpretation is carried forward, then every aspirant, candidate, student, citizen of this country, who achieves or is declared as a top ranker in every stage of examination, would be entitled to protection of their 'personality rights'," he added.

The Delhi High Court observed that while personality rights have been recognised in cases involving individuals with sustained public recognition and commercial value attached to their persona, the threshold cannot be diluted to cover isolated academic accomplishments.

"Though the courts have not been able to concisely or precisely define ‘personality rights’, it is prudent to avoid such enlargement and widening of the scope to the levels of incongruity and absurdity," the order said.

The observations came against the backdrop of a dispute involving claims over the success of a minor student who secured All India Rank 1 in CLAT 2026, with rival coaching institutes accusing each other of misleading publicity and defamatory campaigns.

At the same time, the Delhi High Court said that the minor’s position appeared to be distinct from that of the coaching institutes involved in the dispute, remarking that "her situation seems to be that of a pawn" in a larger rivalry between competing edtech entities.

"It was not appropriate for the defendant nos. 1 and 2 to carry out any campaign, whether defamatory or otherwise, in the name of plaintiff no.3," Justice Gedeala observed, adding that the student had already clarified her position and requested that her name not be dragged into the controversy.

While refraining from conclusively adjudicating the issue of personality rights at this stage, the order clarified that the present case could not be decided on that basis alone.

On a prima facie assessment, the Delhi High Court found that the defendants’ posts, blogs, and videos appeared to be disparaging and intended to tarnish the reputation and goodwill of the plaintiffs, including through unauthorised use of their registered trademark “LegalEdge”.

Describing the dispute as an "acrimonious professional rivalry", it held that attempts to lower the image of a competitor through such content "cannot be countenanced".

Accordingly, the Delhi High Court granted an ex parte ad-interim injunction restraining the defendants from publishing or circulating defamatory, disparaging, or infringing content against the plaintiffs across digital platforms.

It also directed that the defendants refrain from using the minor student’s name, images, or AI-generated representations, and barred them from tampering with any material related to the alleged campaign.

Further, intermediaries, including Google and Meta, were directed to take down or disable access to the identified defamatory content within 72 hours. The matter will be heard next after the completion of pleadings.

--IANS

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