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ARTICLE · 28 JANUARY 2026

When The Internet Refuses To Move On: Media Reporting, Discharge And Dignity

In the case of IE Online Media Services Private Limited v. Nitin Bhatnagar and Ors.

IndiaMedia, Telecoms, IT, Entertainment

Recently, the High Court of Delhi ("High Court") upheld an interim injunction directing restraint on the continued circulation and indexing of news reports concerning an individual who had been arrested and subsequently discharged and criminal complaints against them withdrawn altogether. This decision underscores the constitutional limits of post-discharge media reporting and affirms that the freedom of the press under Article 19(1)(a) must, in appropriate cases, yield to an individual's right to dignity, privacy, and the right to be forgotten under Article 21 of the Indian Constitution.

Background of the Case

This case arose out of an appeal filed by a news publishing company ("Appellant") under Order XLIII Rule 1(r) of the Code of Civil Procedure, 1908 ("CPC"), challenging an interim order ("Impugned Order") passed by the Principal District and Sessions Judge, Patiala House Courts, New Delhi ("Trial Court"). The Impugned Order had granted interim relief in favour of the

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