Isha Foundation Defamation Case: Court orders Google to take down 44 more "per se defamatory" videos and articles.

The Plaintiff, Isha Foundation, filed an application under Section 151 of the CPC seeking clarification of an interim order dated 19.03.2026.

In the original order, the Court directed the removal of defamatory videos/articles listed in Paragraphs 10 and 25–51 of I.A. No. 30090/2025.

The Plaintiff contended that while the previous order covered 11 main videos, it inadvertently omitted 39 short videos and 5 English language videos mentioned in Paragraph 10 of the Plaint, which contain identical defamatory content.

The Defendants opposed the application, arguing it was an attempt to seek a review and expand the scope of the original injunction.

1. Whether the application for "clarification" is actually an application for modification of the prior interim order.

2. Whether the 39 short videos and 5 English language videos mentioned in the Plaint are subject to the same injunctive reliefs granted in the order dated 19.03.2026.

Section 151 of the Code of Civil Procedure, 1908, which recognizes the inherent powers of the Court to make such orders as may be necessary for the ends of justice or to prevent abuse of the process of the Court.

The principle that if a subsequent application seeks reliefs that are part and parcel of the original pleadings (by way of incorporation by reference in the interlocutory application), such reliefs are not "alien" to the original adjudication.

The Court observed that although the application was styled as one for "clarification," it was effectively seeking a "modification" of the 19.03.2026 order.

The Court noted that Paragraph 25 of the original stay application (I.A. No. 30090/2025) explicitly incorporated the contents of the Plaint as "part and parcel" of the application.

Since Paragraph 10 of the Plaint specifically detailed the 39 short videos and 5 English language videos, and since the Court had already found the content therein to be per se defamatory in its previous order, a separate adjudication for these specific links was unnecessary.

The Court reasoned that the modification was necessary to uphold the "spirit" of the original order and ensure the effective removal of identical defamatory content.

The Court modified Paragraph 59 of the Order dated 19.03.2026 to expressly direct Defendants No. 1 and 3 to bring down the 39 short videos and 5 English language videos mentioned at Paragraph 10 of the Plaint.

The Court ordered that this judgment be read conjointly with the original order dated 19.03.2026.