Madras High Court
REV.APLO/13/2026 of Google LLC Vs DAULAT JAIN AND 16 OTHERS on 3 November 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 03-11-2026
CORAM
THE HON'BLE MR.JUSTICE P. DHANABAL
REV.APLO No. 13 of 2026 and Application No.1932 of 2026
in C.S. No.456 of 2019
Google LLC
Rep. by its Chief Executive Officer,
1600, Amphi theatre Parkway, Mountain View, CA 94043, United States of America.
..Petitioner(s)
Vs
1. Daulat Jain And 16 Others
S/o.Late Sardarmallji Jain, No.55, Narayana Mudali Street, Sowcarpet, Ch-79
2. Rajesh Jain
S/o.Late Sardarmallji Jain, No.55, Narayana Mudali Street, Sowcarpet, Ch-79
3. Mr.Mahesh Jain
S/o.Late Sardarmallji Jain, No.55, Narayana Mudali Street, Sowcarpet, Ch-79
4. M/s.Times of India
Rep.by its Editor, Kochar Towers, No.19, Venkatnarayana Road, T.Nagar, Parthasarathi Puram, Chennai - 17 And also at Plot No.391, Ecstsy IT Park, Udyog Vihar Phase - 3, Gurgaon, Haryana - 122016.
5. M/s.Economic Times
Rep.by its Editor, Kochar Towers, No.19, Venkatnarayana Road, T.Nagar, Parthasarathi Puram, Chennai - 17 And also at Plot No.391, Ecstasy IT Park, Udyog Vihar Phase - 3, Gurgaon, Haryana - 122016.
6. M/s.Sunday - Guardian.com.
Rep. by its Editor, B-4, Noida Sector 3, Noida, Uttar Pradesh - 201 301.
7. M/s.Hindustan Times
Rep. by its Editor, Hindustan Times House, 18- 20, Kasturba Gandhi Marg, New Delhi - 110
001.
8. M/s.Tahelka.com
Rep. by its Editor, Anant Media Pvt. Ltd., Building No.23, Nehru Place, New Delhi - 110
019.
9. Offshoreleaks.icij.org
Rep. by its Chief Executive Officer,
International Consortium of Investigative Journalist, 1710, Rhode Island Ave NW, 11th Floor, Washington DC 20036, United States of America.
10.Rediff.com
Rep. by its Editor, Mahalaxmi Engineering Estate, No.1, L.J.Road, Mahim (West), Mumbai
- 400 016.
11.One India News
Rep. by its Editor, One.in Digitech Media Private Limited, Nadathur Place, Plot No.23, 8th Main, 3rd Block, Jayanagar, Bengaluru - 560 011.
12.DNAI.in
Rep. by its Editor, Diligent Media Corporation Ltd., 11th Floor, Tower 3, India Bulls Finance Centre, Senapati Bapat Marg, Elphinstone (West), Mumbai - 400 013
13.M/s.Business Standard
Rep. by its Editor, Business Standard Pvt. Ltd., Nehru House, 4, Bahadur Shah Zafar Marg, New Delhi - 110 002.
14.M/s.Daily Pioneer
Rep. by its Editor, The Pioneer, CMYK
Printech Ltd., F-31, Sector 6, Noida, Uttar Pradesh - 201 301.
15.M/s.Outlook India
Rep. by its Editor, AB-10, Block A 1 Nauroji Nagar, Safdarjung Enclave, New Delhi 110
029.
16.M/s.Deccan Herald
Rep. by its Editor,
The Printers (Mysore) Pvt. Ltd., 75 MG Road, PO Box No.5661, Bengaluru 560 001.
17.Press Reader International Limited
Rep. by its Chief Executive Officer, 2nd Floor, The Boat House, Bishop Street, Dublin 8, D08
H01F, Ireland
..Respondent(s)
PRAYER: The Review application (Original Side) has been filed under Order XIV Rule 8 of Original Side Rules read with Order XLVII Rule 1 and Section 114 of the Code of Civil Procedure praying to review the Judgment of this Honble Court dated 30/01/2026 in C.S.No.456 of 2019.
For Petitioner(s):
G.Balasubramanian for M/s.Leela And Co
For Respondent(s):
Mr. Jayesh B Dolia, Senior Counsel for
M/s.Aiyar And Dolia,
assisted by
Mr. Sri Vijai.S [for R1 to R3]
R4 to R17 – Given up vide B/O dated 27.08.2026.
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ORDER
This application has been filed by the review applicant to review the judgment of this Court dated 30.01.2026 passed in the main Suit.
2. According to the review applicant, the Suit was instituted by the respondents 1 to 3 seeking reliefs of permanent injunction restraining the defendants or others, their men, agents, servants or any other person or persons claiming through them publishing / posting any articles in magazines, posters, newspapers, articles in the websites against the Plaintiffs and their business entities JG Group of Companies, which would tarnish the goodwill and reputation of the Plaintiffs connecting them to the alleged 2G scam and sought for a direction to the defendants or others to permanently remove the defamatory contents tarnishing the Plaintiffs and their business entities from their respective websites in connection with the alleged 2G scam. However, this Court granted relief neither pleaded nor prayed for by the Plaintiffs. Therefore, this contradiction has given apparent error on the face of the record. At no point in the Plaint, the Plaintiffs have pleaded or prayed for a mechanism whereby they would provide requests for the removal of content to the applicant nor have they prayed that the Court direct the applicant to remove such content. Despite this, the impugned judgment has travelled beyond the pleadings and has issued such a direction. Therefore, filed this review application.
3. The respondents have filed a counter denying the grounds raised in the review application. According to the respondents, the review application is an after-thought and has been filed only subsequent to the respondents issuing a representation dated 24.02.2026 to the applicant pursuant to the liberty granted by this Court in the judgment dated 30.01.2026. Immediately upon receipt of the said representation identifying the specific URLs, the applicant has approached this Court by filing the present review application in order to circumvent and defeat the obligation imposed upon it by this Court to remove the identified content within 15 days. The present review application has been filed not on account of any genuine error in the judgment, but solely as a tactic to avoid compliance with the direction of this Court. The ground raised by the applicant that the direction issued by this Court travels beyond the pleadings and prayers of the Plaintiffs, is wholly untenable. The Plaintiffs had approached this Court seeking removal of defamatory content linking them with the alleged 2G Spectrum scam and for appropriate directions against the defendants including the applicant. Therefore, prayed to dismiss the application.
4. This Court heard both sides and perused the materials available on record.
5. The main ground raised by the review applicant to review the judgment is that the Plaintiffs have failed to identify and to set out the exact defamatory content by way of transcripts and specific URLs in the Plaint, which is the fundamental requirement in a defamation action. N
o supporting documents have been filed to substantiate the allegation of defamation. The Plaintiffs have neither provided any transcripts of the allegedly defamatory contents mentioned in the Plaint, nor have they provided details pleadings on the specific unlawful or defamatory contents which are sought to be removed. At no point in the Plaint, the Plaintiffs have pleaded or prayed for a mechanism whereby they would provide requests for the removal of content to the applicant nor have they prayed that the Court direct the applicant to remove such content.
6. In fact, the Plaintiffs, in the Suit, have sought for (a) For a permanent injunction restraining the defendants or others their men, agents, servants or any other person or persons claiming through them from publishing/ posting any articles in magazines, posters, newspapers, articles in the websites against the plaintiffs and their business entities JG Group of Companies, which would tarnish the goodwill and reputation of the plaintiffs connecting them to the alleged 2G Scam; (b) For a Mandatory Injunction directing the defendants or others to permanently remove the defamatory contents tarnishing the Plaintiffs and their business entities Doulat Jain, Rajesh Jain, Mahesh Jain and JG Group of Companies from their websites in relation to the alleged 2G Scam; (c) For a Mandatory Injunction directing the defendants or others to publish an article stating the allegations mentioned earlier in their website tarnishing the image of
Plaintiffs and their business entities JG Group of Companies with respect to the alleged 2G Scam, was found to be false and seek an apology in public domain and for costs. This Court, after taking into consideration the arguments adduced on both sides and the defendants themselves agreed to remove the contents and there are no allegations as against the review applicant in the Suit, who has been arrayed as 3rd defendant and only because of the alleged contents hosted in the platform of the 3rd defendant, he has been added as party, but without any particulars to identify the contents, this Court observed that it is not appropriate to grant decree as against the 3rd defendant. Since the claim against the main defendants, who published the articles, has been ‘not pressed’ by the Plaintiffs, this Court granted liberty to the Plaintiffs that if they are able to identify the content transcription and the specific URL identity, then they can make representation to the 3rd defendant within one month from the date of receipt of a copy of the judgment and after receipt of such request, if any, the 3rd defendant has to remove the said contents within 15 days from the date of receipt of such request from the Plaintiffs. Once the Plaintiffs identified the content transcription and the specific URL identity, then it is the duty of the review applicant to remove the contents as directed by this Court. The grounds raised by the review applicant have already been answered by this Court in the judgment, since the same grounds were raised before this Court and there are no grounds to review the judgment passed by this Court. If at all the petitioner is aggrieved by the judgment of this Court, he ought to have filed appeal as against the judgment and decree, instead, he filed this review petition without any grounds.
7. Therefore, this Review Application has no merits and deserves to be dismissed.
8. Accordingly, this Review Application (Original Side) is dismissed. There shall be no order as to costs. Consequently, the connected application is closed.
03-11-2026 MJS
P.DHANABAL, J. MJS REV.APLO No. 13 of 2026 in C.S. No.456 of 2019 03-11-2026