Info Edge India Ltd vs Synapseindia Outsourcing Pvt Ltd & Anr.
- Court
- Delhi High Court
$~12
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Date of Decision: 10.04.2026
+ FAO (COMM) 54/2026 CM APPL. 11603/2026
INFO EDGE INDIA LTD .....Appellant
Through: Ms Swathi Sukumar, Sr. Advocate
with Mr. Rishabh Sharma, Mr. Aman
Taneja, Ms. Vanshika Thapliyal and
Ms Ambica Sood, Advocates
versus
SYNAPSEINDIA OUTSOURCING PVT LTD & ANR.
.....Respondents
Through: Mr. Bhuvanesh Sehgal, Advocate
CORAM:
HON'BLE MR. JUSTICE V. KAMESWAR RAO
HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA
MANMEET PRITAM SINGH ARORA, J. (ORAL)
1. The present appeal has been filed by the Appellant against the order
dated 15.01.2026 [‘impugned order’] wherein the District Judge
(Commercial Court) - 06, South East, Saket Courts, Delhi, has allowed the
Respondent’s application under Order XXXIX Rule 1 & 2 CPC read with
Section 151 of the Code of Civil Procedure, 1908 (CPC), in the matter titled
SynapseIndia Outsourcing Pvt. Ltd. & Anr. v. Info Edge (India) Ltd.
CS(COMM) NO. 728/ 2025. The relevant portion of the interim injunction
granted reads as under:
“29. Consequently, till further orders, an ad-interim order of injunction is
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passed in favour of the Plaintiffs and against the Defendant restraining
Defendant from using the trade name of the Plaintiff No.1 i.e.
" SynapseIndia " and " Synapselndia I.T. Outsourcing @ Peace of
Mind " on its web-portal i.e. www.ambitionbox.com for
inviting/permitting users to post reviews about its work culture or
otherwise in respect or in relation to the Plaintiffs. Time of 72 hours
from today is given to the Defendant for ensuring compliance of the said
direction.
30. Further, Plaintiffs are at liberty to file application to the Defendant
and/or to the Defendant through Counsel for removal of the comments
/posts on the platform of Defendant mentioning the details of the same
and Defendant is directed to remove the same within 36 hours of
receiving the said application from the Plaintiffs.”
2. The impugned order was passed in a suit, wherein the Respondents
alleged trade mark and copyright infringement, passing off and defamation
on account of certain negative reviews posted by users on the Appellant’s
platform ‘AmbitionBox’. The Respondents stated that the Appellant created
a page on its platform enabling users to post reviews about the Respondents’
company without their express permission, and thus used their trade mark
without prior authorisation. It was the stand of the Respondent that
Appellant’s platform permitted posting of reviews without verification if the
‘user, posting the specific content, had actually worked with the company or
not. It was contended that the objected to, negative reviews were ex-facie
fake and were causing damage to the goodwill and reputation of the
Respondent/plaintiffs.
3. However, it is the stand of the Appellant that the Appellant provides a
neutral online platform i.e. www.ambitionbox.com, that permits its
registered users to post company reviews and salary insights etc. It is a user-
driven platform which hosts third-party content in the form of reviews and
ratings, and serves as an important source of information for job seekers to
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evaluate the work culture, compensation etc. at prospective employer
organisation. The Appellant neither initiates, authors, edits, selects the
receiver of, modifies nor endorses such content.
3.1. It is stated that the platform of the Appellant does not exercise
editorial control over ‘user’ reviews. It publishes and informs the users
about its Community Guidelines, Terms of Use and Privacy Policy. Further,
the Appellant has a multi-tier content review mechanism to take down any
content which does not adhere to its Community Guidelines.
3.2. It is stated that the Impugned Order effectively compels the Appellant
to apply its own mind to whether the content on its platform should or
should not be blocked, proactively screen user content, and publish only
“bonafide, identified and factual reviews”.
3.3. It is contended that anonymity on the Appellant’s platform is designed
to protect free speech of employees against employers. It is because of this
model that several users feel comfortable in speaking up, sometimes to
highlight inter alia workplace harassment, favouritism, biasness or pay
disparity etc. It is stated that the Trial Court has failed to recognise the
fundamental right to free speech of users of the platform. The directions
operate as a pre-trial gag order, curtailing speech and criticism in the garb of
trade mark protection.
4. Conversely, the Respondent has also, seriously contested that the
Appellant is not an intermediary and states that the Appellant is not entitled
to safe harbour under Section 79 of the IT Act, 2000. It contends that the
impugned order was passed by the Trial Court after reviewing the lack of
verification by the Appellant and anonymity of the opinions posted by the
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users on this platform.
5. After some arguments, learned counsel for the Appellant states on
instructions that Appellant is willing to have the appeal disposed of and suit
itself decreed in terms of its undertaking dated 10.04.2026, which reads as
under: -
It is humbly submitted that the Impugned Order may be set aside in view
of the undertakings herein. Without prejudice to the Appellant's case that
the Respondent's suit is misplaced and incorrect, the Appellant is willing
to tender the following undertakings:
1. That the Appellant provides a neutral online platform i.e.
www.ambitionbox.com that permits its registered users to post company
reviews and salary insights etc. The Appellant neither initiates, authors,
edits, selects the receiver of, modifies nor endorses such content.
2. As on date, the Appellant allows its users to login either through their
Gmail or LinkedIn or Microsoft 365 or Naukri.com account. In addition
to the login details, the platform also records IP address and time stamp
etc of the users posting reviews. All users accept the terms and conditions
that they will not misuse the anonymity of the platform and to respect the
community guidelines and the terms and conditions of the platform
'AmbitionBox'.
3. In relation to the Respondents, the Appellant undertakes to use the
Respondents' name/ mark only as an identifier to enable its registered
users to comment and review the Respondents' company and share salary
insight etc. in accordance with the Appellant's terms of use and
community guidelines.
4. While the Appellant maintains a robust content review and
moderation mechanism which prohibits and removes abusive and other
kinds of problematic content (gibberish, not necessarily negative
reviews), it is possible that certain at-issue content may get uploaded by
the users.
5. In case, the Respondents are aggrieved by any such content, they can
reach out to the Appellant at [email protected]. The Appellant
undertakes to review the reported content within 48 hours on working
days and provide an update to the Respondents.
6. Thereafter, the Appellant will immediately remove the content as
provided under the Information Technology (Intermediary Guidelines
and Digital Media Ethics Code) Rules 2021 (as amended from time to
time, in Clause 3(1)(b), if the Respondents furnish any of the following:
(a) Court order; or (b) notification by the Appropriate Government or its
agency.
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7. If the reported content is established on the face of it be a fake review
(for eg: review suggesting that the Respondents maintain a zoo in their
office, recorded at para 2(q)(ii) in the Impugned Order at Pg. 83-84/ pdf
93-94, then the Appellants will remove it without requiring a court order.
8. Further, even without a court order, if the reported content reveals
confidential information, such as source code, manufacturing techniques,
R&D activities, and detailed financial results, the Appellant will remove
it within the afore-mentioned timeline.
9. The Appellant requires the reported content to be identified by its
URL, by email to the Appellant on [email protected], so as to
expeditiously act upon the Respondents' complaint.
10. For any at-issue content, pursuant to an appropriate order by a court
of law or a request from a law enforcement agency against the Appellant
for a particular post, the Appellant will furnish the user details as
maintained by it. This will include the user credentials (used to create the
account, IP address, and timestamps).
A copy of the undertaking has been handed over by the learned
senior counsel for the Appellant.
6. Learned senior counsel for the Appellant states that the suit may be
decreed in terms of the abovementioned undertaking and in case of any
breach of terms of this undertaking, the Respondent can have the remedy, to
have the same implemented, through execution proceedings.
6.1. She clarifies that with respect to the undertaking, at para no. 10, it is
the stand of the Appellant that in respect of the ‘at-issue content’, which the
Appellant refuses to take down and if the Respondent is dissatisfied with the
decision of the Appellant, Respondent will be at liberty to approach the
Executing Court to raise the issue; and if the Executing Court agrees with
the Respondent’s grievance and directs the Appellant to provide the user
credentials, Appellant shall do so.
6.2. She relies upon Section 72A of the Information and Technology Act,
2000 (‘Act of 2000’) to contend that if the ‘at-issue content’ does not fall
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foul of Rule 3(1) of the Rules, 2021 and/or the Community Guidelines of the
Appellant’s platform, the Appellant will not be in a position to either take
down the review or provide the user detail information to the Respondent,
on its request alone. She states that in such a situation the Respondent may
provide a Court order to the Appellant from the Executing Court.
7. Mr. Sehgal, learned counsel for the Respondent states that while
Respondent has no objection to the suit being decreed in its favour and
against the Appellant in terms and conditions of the undertaking, however,
he states that the Respondent is not conceding to the stand of the Appellant
that it is an intermediary which is entitled to protection under Section 79 of
the Act of 2000. He states that, however, since the suit is being disposed of
with consent of the rival parties, the said issue may be left open, so as to not
curtail the rights of the Respondent in case any disputes arise in future.
7.1 He states that Respondent should be permitted to respond to the
comments posted by the user, without any condition for payment of charges
or subscription.
Learned counsel for the Appellant clarifies that the feature to respond
is available on the platform without any charges and in fact, in the past
Respondent has availed the said facility.
7.2 He submits that the comments on the old page which was taken down
by the Appellant in pursuance of the impugned order are no more available
and Appellant should not restore the said comments and initiate a fresh page,
instead.
Learned counsel for the Appellant states that in compliance with the
impugned order it had taken down the page of the Respondent hosted on its
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platform and therefore currently no comments are available on its platform.
It submits that in view of the order passed today, it will host a fresh page for
the Respondent company, not reactivate the old page and therefore the old
comments will not be visible.
8. We have heard the learned counsels for the parties.
9. We have perused the undertakings given by the Appellant and the
submissions of the learned counsel for the Appellant, qua para no. 10 of the
undertaking. The parties have agreed to have the appeal disposed of and the
suit decreed in terms of this order.
10. We take the undertakings of the Appellant on record and direct that
the Appellant shall remain bound by the said undertakings, the submissions
of its senior counsel recorded at paragraph 6.1, 7.1 and 7.2 of this order, as
well as the directions issued hereinafter.
11. With respect to ‘at-issue content’ stipulated at para no. 10 of the
undertaking, we clarify that in case the Respondent is aggrieved by the
Appellant’s stand on ‘at-issue content’, it will be at liberty to file an
appropriate Execution Application to raise the said issue and if the
Executing Court finds merit in the submission of the Respondent, it shall
issue appropriate directions to the Appellant herein to furnish the user details
of the person who published the objected/negative reviews; and thereafter,
the Appellant will take action against the said user in accordance with law.
12. In view of the undertakings and the order passed today, the interim
injunction order dated 15.01.2026 is therefore, set aside. The Appellant will
be at liberty to host a fresh page pertaining to Respondent company and
permit posting of user comments qua the Respondent. The Appellant will
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commence the platform qua the Respondent on a clean slate. In case,
Respondent has any concerns about the fresh user comments, it will exercise
its rights in accordance with terms and conditions set out in this order.
13. With the consent of the parties, the suit itself is decreed in terms of
this order. A decree shall be drawn up in favour of the Respondent/plaintiff.
The Respondent/plaintiff will be entitled to seek execution of the decree in
case of any violation and/or breach by the Appellant/defendant as well as for
user credentials in case of an ‘at issue content’.
14. We clarify that since the matter has been settled between the parties
through consent, the issue raised by the Respondent/plaintiff in suit seeking
a declaration that Appellant/defendant is not an intermediary is left open,
and the passing off this decree shall not be construed as issue estoppel
against the Respondent/plaintiff, if future disputes arise between parties. The
Respondent/plaintiff will be entitled to agitate the said issue in future
disputes, which needless to state will be decided in accordance with law.
15. The appeal is hereby disposed of. Pending applications, if any, are
disposed of.
16. The Appellant is directed to file an affidavit of its Director and/or
authorised representative from Senior Management affirming the
undertaking and this order within two (2) weeks. Copy of the board
resolution evidencing that this order has been noted by the Board in its
minutes and authorised the Director and/or authorised representative to file
the affidavit shall be placed along with the said affidavit.
17. The Registry is directed to send this order to the Trial Court via e-
mail on the next date of hearing i.e., 15.04.2026 on which date the Trial
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Court will take on record this order and close the proceedings. The Registry
of Trial Court is directed to draw up a decree sheet in terms of this order.
MANMEET PRITAM SINGH ARORA, J
V. KAMESWAR RAO, J
APRIL 10, 2026/mt/IB
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