Madras HC Rejects Google’s Review, Leaving 15 Days to Remove Plaintiffs’ Identified Content Linked to the Alleged 2G Scam

In brief

The question

Whether the direction requiring Google to remove content identified by the plaintiffs went beyond the pleadings and prayers and constituted an apparent error warranting review.

The court held

The Court dismissed the review application for lack of merit, made no order as to costs, and closed the connected application.

01Facts

Daulat Jain and two others had sued, among others, Google LLC, seeking injunctions against publication of material linking them and their business entities to the alleged 2G scam, removal of allegedly defamatory content, and other reliefs.

pp. 4, 6–7

In its judgment dated 30 January 2026, the Court declined to grant a decree against Google but gave the plaintiffs liberty to identify the relevant content and URLs and make a representation to Google; it directed Google to remove identified content within 15 days of receiving such a request.

p. 7

Google sought review, arguing that the direction went beyond the pleadings and prayers and that the plaintiffs had not specified the allegedly defamatory content or URLs in the plaint.

pp. 4–6

The plaintiffs opposed review, alleging that it was filed to avoid compliance with the direction.

p. 5

02Issues

i.Whether the direction requiring Google to remove content identified by the plaintiffs went beyond the pleadings and prayers and constituted an apparent error warranting review.

pp. 4–6

ii.Whether Google’s grounds, including the plaintiffs’ failure to specify transcripts and URLs in the plaint, established a basis to review the judgment.

pp. 5–7

03Law Applied

The application was brought under Order XLVII Rule 1 and Section 114 of the Code of Civil Procedure, read with Order XIV Rule 8 of the Madras High Court Original Side Rules.

p. 3

The Court did not cite any precedent or set out a separate, detailed test for review. It held that the grounds raised had already been considered in the original judgment and that a party aggrieved by that judgment ought to pursue an appeal rather than seek review on those grounds.

p. 7

Provisions in the judgment · 1 · Linked ones open on LawLens

Code of Civil Procedure, 1908 Section 114

04Reasoning

The Court examined the reliefs sought in the suit and the original judgment. It noted that the plaintiffs had sought removal of defamatory content, but the Court had not granted a decree against Google; instead, it had provided a process for the plaintiffs to identify specific content and URLs and then request their removal.

pp. 6–7

The Court considered Google’s objections—including the alleged absence of specific content and URLs in the plaint—to have already been addressed in the original judgment. It therefore found no ground to review that judgment and observed that an appeal, rather than review, was the appropriate remedy if Google remained aggrieved.

p. 7