Justice A.J.Bhambhani Delhi HC INTERIM PROTECTION Court splits 6,884 URLs toprotect personality rights
[ High Court of Delhi ]

Delhi HC Orders Removal of 552 Pornographic URLs Targeting Janhvi Kapoor, Refuses Blanket Injunction Over 6,884 URLs

Justice A. J. Bhambhani directed defendants 20 and 21 to take down 552 sexually vulgar URLs within three weeks, while declining a sweeping order covering all 6,884 disputed links pending classification by the plaintiff's counsel.

The High Court of Delhi, in a commercial suit filed by actor Janhvi Kapoor, passed a targeted interim order on 11 August 2026 directing the removal of 552 URLs found to be ex facie grossly sexually vulgar or pornographic. Justice A. J. Bhambhani, sitting singly, declined to grant the blanket injunction the plaintiff sought across all 6,884 URLs made subject matter of the suit, finding the claims and prayers “over-broad, not only because of the nature of relief sought” but also given the sheer volume and variety of the impugned digital content. The court simultaneously disposed of four interlocutory applications concerning pre-litigation mediation, evidentiary certificates, government notice requirements, and court-fee timelines.

The Suit and the Scale of the Dispute

Janhvi Kapoor filed CS(COMM) 868/2026 before the Delhi High Court, arraying multiple defendants including individuals identified as Ashok Kumar or John Doe, as well as technology platforms and government authorities. The suit targets a total of 6,884 URLs spread across various categories of digital content, ranging from allegedly pornographic material to content said to monetise her personality rights or use her name and likeness to promote merchandise and services.

The scale of the relief sought — injunction or takedown of all 6,884 URLs in a single sweep — drew close scrutiny from the court at the very first hearing. After what the order describes as a “very detailed hearing,” Justice Bhambhani concluded that an undifferentiated blanket order was not appropriate and directed the plaintiff's counsel to classify the disputed URLs into three distinct categories before the matter is taken up further.

Pre-Litigation Mediation Exemption

Before the main injunction application was addressed, the court dealt with I.A. 21555/2026, by which the plaintiff sought exemption from attempting pre-litigation mediation under section 12A of the Commercial Courts Act, 2015 read with section 151 of the Code of Civil Procedure, 1908.

The court allowed the exemption relying on two precedents: the Supreme Court's judgment in Yamini Manohar v. T.K.D. Keerthi, reported at (2024) 5 SCC 815, and a Division Bench judgment of the Delhi High Court in Chandra Kishore Chaurasia v. R A Perfumery Works (P) Ltd., reported at 2022 SCC OnLine Del 3529. The application was disposed of accordingly.

Three other interlocutory applications were also dealt with at this stage. The court exempted the plaintiff from filing the certificate or affidavit required under section 63(4)(c) of the Bharatiya Sakshya Adhiniyam, 2023, subject to the document being filed within two weeks. It waived the requirement of a two-month prior notice to the government authority defendants (defendants 20 and 21) under section 80 of the CPC, on the basis of facts stated in the application supported by affidavit. It also extended time for filing the requisite court fees, again by two weeks.

Why the Court Refused a Blanket Injunction

On the main application for an ex parte ad-interim injunction filed under Order XXXIX Rules 1 and 2 read with section 151 of the CPC, the court did not find the plaintiff's case entirely without merit. However, it drew a clear distinction between targeted relief and a wholesale takedown order.

The court's reasoning turned on two factors. First, the nature of relief sought was itself over-broad. Second, relief had been claimed against 6,884 URLs across various categories, which the court found made a uniform injunction unworkable and disproportionate without further sorting. The court therefore directed counsel for the plaintiff to set out the thousands of URLs in tabular form, classified into three categories:

  • Content that is ex facie pornographic and sexually vulgar;
  • Content that can ex facie be seen to directly monetise the plaintiff's personality rights; and
  • Content that uses the plaintiff's name and likeness to indirectly promote the sale of merchandise and services.

This classification exercise was made a precondition for any further consideration of the broader injunction prayer. The approach reflects a reluctance to allow injunctive relief to operate as a dragnet across categories of content that may attract different legal standards and defences.

Targeted Relief: URLs 1 to 552

While declining the blanket order, Justice Bhambhani did grant limited interim relief in respect of the first 552 URLs listed in the annexure to the plaint. On a preliminary appreciation, the court found those URLs to be ex facie grossly sexually vulgar or pornographic content that evidently did not carry any permission from the plaintiff.

Applying the standard three-part test for interim injunctions, the court held that the plaintiff had made out a prima facie case, that the balance of convenience lay in her favour and against the defendants, and that irreparable loss and injury would be caused if interim relief were not granted for this subset of URLs.

Defendants 20 and 21 — the government authority defendants — were directed to forthwith remove or take down the 552 URLs within three weeks of the order dated 11 August 2026.

Procedural Directions and Party Correction

The court directed that the plaint be registered as a suit and issued summons. Counsel appearing on record for several defendants — including representatives for defendant 3/Meta, defendant 4, defendant 6, defendants 10 and 11, and defendant 12 — accepted summons on advance copy and sought time to file written statements.

One procedural correction arose at the first hearing itself. Counsel for defendant 12 pointed out that the correct legal entity that ought to have been impleaded was GoDaddy.Com LLC, not GoDaddy India Web Services Private Limited. The court directed the plaintiff to file an amended memo of parties substituting defendant 12 with the correct entity before summons are sent to remaining defendants.

Written statements are to be filed within 30 days along with affidavits of admission or denial of the plaintiff's documents. The plaintiff may file replications within 30 days of receiving the written statements, along with corresponding affidavits.

Outcome

I.A. 21555/2026 (pre-litigation mediation exemption), I.A. 21556/2026 (section 63(4)(c) certificate exemption), I.A. 21557/2026 (section 80 notice waiver), and I.A. 21558/2026 (court-fee extension) were all disposed of. On I.A. 21554/2026, the main injunction application, the court issued notice, declined a blanket injunction over all 6,884 URLs, and directed removal of URLs at serial numbers 1 to 552 of the plaint annexure within three weeks. The matter was re-notified for 17 August 2026.