Single Achievement No Basis For Claiming Personality Rights: Delhi High Court In Dispute Involving CLAT Topper Geetali Gupta, LegalEdge
The Court clarified that personality rights cannot be claimed merely based on a singular success, cautioning against an over-expansive interpretation that could lead to incongruous results.
Justice Tushar Rao Gedela, Delhi High Court
The Delhi High Court has observed that a single instance of success or achievement cannot, by itself, be elevated to claim protection under “personality rights”, cautioning that such an interpretation would lead to incongruity and absurdity.
The Court was hearing a commercial suit seeking injunctive relief against alleged defamatory and disparaging content, including unauthorised use of the identity of CLAT 2026 topper Geetali Gupta and the “LegalEdge” trademark by Law Prep Tutorial.
A Bench of Justice Tushar Rao Gedela observed: “… any and every success, or a milestone achieved, is held to be sufficient to be raised to the level of a 'personality right’; it would lead to absurdity and incongruity, … if such an interpretation is carried forward, then every aspirant, candidate, student, citizen of this country, who achieves or is declared as a top ranker in every stage of examination would be entitled to the protection of their personality rights”.
J. Sai Deepak, Senior Advocate with Advocates Ankur Khandelwal, Chirag Sharma, Nikhil Saurabh and Sidhhi appeared for the Plaintiffs.
Background
The dispute arose out of a commercial suit filed by the plaintiffs, including CLAT 2026 All India Rank 1 holder Geetali Gupta, along with entities associated with the “LegalEdge”, alleging that the defendants, operating under the brand “Law Prep Tutorial”, had engaged in unauthorised use of her identity and the plaintiffs’ trademarks.
It was the case of the plaintiffs that, despite refusal of consent, the defendants continued to portray Geetali Gupta as their student across blogs, social media posts and video content, while simultaneously publishing material containing allegations against the plaintiffs.
The plaintiffs contended that such use of the name, image and achievement of Geetali Gupta, coupled with the use of the trademark “LegalEdge”, was misleading and had resulted in reputational harm.
It was further alleged that the content circulated by the defendants, including posts and video reels, amounted to a disparaging campaign intended to bring disrepute to the goodwill and standing of the plaintiffs.
On these grounds, the plaintiffs sought an ex-parte ad-interim injunction restraining the defendants from continuing such use and publication.
Court’s Observation
The Court undertook a detailed examination of the nature of the dispute, including allegations of disparagement, misuse of identity, and claims relating to personality rights.
At the outset, the Court observed that the material placed on record indicated a prima facie case of disparagement, noting that the content “appears to be… an attempt to bring to disrepute the goodwill and reputation” of the plaintiffs.
It further held that the defendants had used the identity of the student in a manner that was not justified, observing that “it was not appropriate for the defendants to carry out any campaign, whether defamatory or otherwise, in the name of plaintiff no.3.”
The Court clarified that its observations regarding the student were not based on any claim of personality rights, explicitly stating: “It is made absolutely clear that the aforesaid observations… are not at all based or predicated on the alleged ‘personality rights’…”
The Court cautioned against an over-expansive interpretation of such rights, observing: “If such interpretation is carried forward, then every aspirant, candidate, student, citizen… who achieves… a top ranker… would be entitled to protection of their ‘personality rights’.”
It further noted that the doctrine itself is not precisely defined, stating: “Though the Courts have not been able to concisely or precisely define ‘personality rights’, however, it is prudent to avoid such enlargement…”
The Court delineated the threshold for the invocation of personality rights, observing that “individual achievers who may have achieved continuous top rank results… received awards… artists of repute, business persons recognised globally… political or religious leaders… may… have… ‘personality rights’…”
However, it clarified that a single instance is insufficient, holding “yet it cannot be a sole or a single instance which would lend credence to a person to agitate violation of ‘personality rights’.”
It emphasised that the threshold cannot be reduced to individual events, noting: “The threshold cannot be brought down to individual events… and may be assessed… on a case-by-case basis.”
The Court also relied on earlier precedent on publicity and personality rights, including the judgment in D.M. Entertainment Pvt. Ltd. v. Baby Gift House (2010), to emphasise that such rights are linked to identifiable commercial exploitation of persona and must be applied with caution.
On overall assessment, the Court held that the defendants had prima facie engaged in a disparaging campaign and unauthorised use of trademarks and identity, observing that “the defendants have indeed, prima facie, carried out a defamatory campaign… [which] would constitute disparagement.”
Conclusion
The Court granted interim relief restraining the defendants from publishing or hosting defamatory and disparaging content, using the identity of the student, or infringing the plaintiffs’ trademarks, and directed the removal of such content from online platforms.
The matter has been listed for further proceedings.
Cause Title: Toprankers Edtech Solutions Private Limited & Ors. v. LPT Edtech Private Limited & Ors.