Claim Is Against Settled Principles On Right To Speech: Madras High Court Rejects T. Rangaraj’s Plea Alleging Defamation By Joy Crizildaa
The Madras High Court quoted the sacred couplet No.144 of Thiruvalluvar, saying that 2000 years ago, the famous saint Thiruvalluvar had stated in a sacred couplet about the extra marital relationship of a man beyond the marriage life with his wife and its consequences.
Madras High Court, Joy Crizildaa, T. Rangaraj
The Madras High Court has rejected the Application of actor, chef, and businessman T. Rangaraj, alleging defamation and infringement of personality rights by fashion designer Joy Crizildaa.
Rangaraj sought interim injunction restraining Joy from posting or circulating any false, malicious or defamatory material against him and to remove/delete the alleged false, defamatory Instagram post made in her Instagram profile and any other material or statements including tagging his name in any social media platform.
A Single Bench of Justice N. Senthilkumar held, “… the plaintiff has only identified the second defendant with several links to the YouTube channels and other social media platforms. Absolutely, there is no material before this court except the photographs and the links. Merely furnishing the links and photographs will not be sufficient for the court to prima facie come to the conclusion that there is a violation of personality rights of the applicant/plaintiff and in the absence of any specific allegation made with regard to commercial gain to the defendants, the claim made by the applicant/plaintiff seeking an injunction is against the settled principles on the fundamental rights guaranteed under Article 19(1)(a).”
The Bench remarked that Rangaraj is only making an attempt to shut the voice of the individuals or the social media who are airing their views which are against him.
The Bench also quoted the sacred couplet No.144 of Thiruvalluvar, saying that 2000 years ago, the famous saint Thiruvalluvar had stated in a sacred couplet about the extra marital relationship of a man beyond the marriage life with his wife and its consequences.
Senior Advocate Srinath Sridevan appeared for the Applicant/Plaintiff, while Senior Advocate S. Prabhakaran appeared for the Respondents.
Facts of the Case
The Applicant/Plaintiff-T. Rangaraj is one of the directors in Madhampatty Thangavelu Hospitality Private Limited, which was incorporated in 2010, which deals with catering, and food services. He had featured in a movie called Mehandi Circus in the year 2019 and thereafter another movie titled as Penguin and few other movies. He also took part in a popular TV reality show "Cooku with Comali" Season 5 (2024) where his culinary expertise won him appreciation in the said show. According to the Plaintiff, the Respondent/Defendant had approached him as a professional costume designer during December, 2023, projecting that she was capable of assisting him with his costume designing requirements.
As days rolled on, the professional association extended as a good friendship. It was alleged that the Defendant deceitfully induced the Plaintiff into a relationship of confidence. It was further alleged that when this deceitful relationship continued, suddenly, the Plaintiff, to his shock and surprise came to know in the month of July, 2025 that the Defendant had posted certain defamatory posts, videos and photos as against the Plaintiff which had caused irreparable injury to his personal reputation. It was also alleged that the act of the Defendant was done with an intention to propagate an allegation that there is a marital relationship between the Plaintiff and the Defendant. Hence, he filed a Suit and approached the High Court seeking interim injunction.
Court’s Observations
The High Court in view of the facts and circumstances of the case, observed, “The bare denial of cohabitation by the plaintiff with the first defendant is nothing but an attempt to escape from the clutches of law. The photographs, videos and Whatsapp chats which were shared by the first defendant on the social media and the interview given by the first defendant exposing her cause with regard to her relationship with the plaintiff makes it clear that there exist a substantial issue between the parties. The validity of the marriage between the plaintiff and the first defendant which has taken place on 24.12.2023 as claimed by the first defendant is a subject matter which is out of the purview of this court.”
The Court said that though the Plaintiff claims that he was threatened by using the photos, videos and chats had been uploaded on the social media, there is no iota of material produced by the Plaintiff to show that he has preferred a police complaint as against the Defendant in respect of the threat, coercion or a malicious/scandalous allegations have been levelled against him.
“There is not even a legal notice issued by the plaintiff asking the first defendant to refrain from uploading such videos and photographs. … The averments in the plaint would only prima facie show that there existed a physical relationship between the plaintiff and the first defendant who are not only grown up adults, they are married and having children who are conscious about the impact and the consequence of having a physical relationship out of the marital life which have resulted in the plaintiff and the first defendant to trade charges against each other”, it noted.
The Court was of the view that such photographs and videos cannot be brushed aside on a mere statement that all these photos and videos and Whatsapp chats are fabricated and concocted.
“This kind of a bare denial of relationship cannot be permitted. … the first defendant's reputation is also damaged because of the relationship between the plaintiff and the first defendant. The plaintiff alone cannot claim that his image has been tarnished by the first defendant”, it added.
The Court further remarked that the crocodile tears shed by the Plaintiff disputing the marriage, physical relationship, photographs, videos, Whatsapp chats emanated only when the Defendant aired everything on the social media.
“Several typed sets were filed by the first defendant showing intimate photographs that have been taken by the plaintiff and the first defendant, which would only show that there existed a relationship. As already pointed out supra, the plaintiff himself has clandestinely admitted the existence of a relationship between the parties at paragraph 9 of the Plaint”, it also said.
Moreover, the Court observed that the genuineness of the photos, videos etc. are to be determined only by letting in evidence and these are all matter for trial.
“As the first defendant has produced intimate photographs taken with the plaintiff, the police complaint as against the plaintiff and the finding given by the Tamil Nadu State Commission for Women are all material factors which are steering against the plaintiff, who cannot abridge the evidentiary value of the said materials by claiming it to be fake or obtain protection by seeking an injunction in present suit”, it held.
Conclusion
The Court reiterated that as freedom of speech under Article 19(1)(a) of the Constitution is a fundamental right, there can be reasonable restrictions under Article 19(2), however, there cannot be a blanket order to restrict or refrain the rights of the individual to express their views.
“It is to be noted that the judgments relied by the learned counsel for the 1st defendant would make it clear that the fundamental right to speech is the right conferred on every single citizen and if the personality rights of the plaintiff is violated by circulation of content concerning his personal life in the social media, the plaintiff has to approach the court and establish the commercial exploitation of the personality rights using the said content by the respective persons”, it added.
The Court, therefore, concluded that the prayer sought as against the second Defendant for a blanket direction to remove the videos, photographs, Whatsapp chats, Instagram posts and debates on the issues between the Plaintiff and the first Defendant cannot be granted and as the Plaintiff has not prima facie established his case as against the Defendants 1 and 2 and as the balance of convenience and irreparable injury are in favour of the 1st Defendant, both the interim prayers are rejected.
Accordingly, the High Court dismissed the Applications and rejected the claim of the Plaintiff.
Cause Title- T. Rangaraj v. Joy Crizildaa & Anr. (Case Number: O.A. No.948 of 2025)
Appearance:
Applicant: Senior Advocate Srinath Sridevan and Advocate Vijayan Subramanian.
Respondents: Senior Advocate S. Prabhakaran and Advocate R. Sudha.
