Indian court orders Google to remove URLs from search in defamation case

Principal District and Sessions Judge Anju Bajaj Chandna of the Patiala House Courts in New Delhi directed the removal of approximately 60 URLs related to criminal proceedings against Nitin Bhatnagar, a banker who was discharged from money laundering allegations in August 2024. The court order affects major Indian news outlets including ANI Media, Indian Express, The Hindu, Hindustan Times, and Times of India, along with global search engines and legal databases.

The case centers on Bhatnagar's arrest by India's Enforcement Directorate on August 22, 2023, in connection with a money laundering investigation involving Moser Baer India Limited. He was granted bail on March 14, 2024, and subsequently discharged from the case on August 17, 2024. According to the court order, Bhatnagar filed suit claiming that continued publication and accessibility of articles about his arrest damaged his professional reputation despite his exoneration.

"The plaintiff has been shown as frauduster thereby portraying negative image of the plaintiff," according to Judge Chandna's order. The court found that articles published by defendants portrayed Bhatnagar as an alleged facilitator in money laundering, with phrases the court deemed demeaning in nature continuing to remain accessible worldwide through search engines.

The Delhi court specifically ordered Google LLC and Indian Kanoon to block URLs from search engine access until final disposal of the case. Indian Kanoon operates a legal research website that indexes court orders and judgments from various Indian courts and tribunals. The order affects 60 specific URLs listed in the plaintiff's complaint, spanning coverage from major news organizations and legal databases.

Google responded to the order through Search Console notifications sent to affected website owners. The notice stated that Google received a legal complaint involving a court order and was blocking certain URLs from appearing in Google Search results on country-level services including google.co.in. "Unfortunately the terms of the order prevent us from sharing a copy of the order," according to the Search Console message.

This limitation created immediate challenges for website operators. Indian Kanoon's social media account stated on November 26 that the organization was not aware of any such order and that Google refused to share details. "We can't even verify if there is a court order to this effect," according to Indian Kanoon's statement.

The lack of order disclosure prompted criticism from digital marketing professionals. Gagan Ghotra, an SEO consultant, questioned how site owners could comply with court directives when they possessed no information about which court issued the order or the specific case details. "Google Search Console be telling site owner to speak to a lawyer and at the same time mentioning 'terms of the order prevent us from sharing a copy of the order' how come site owner is supposed to do anything when they don't even know which court and for which case order," according to Ghotra's analysis.

The court order builds on legal precedent established in Indian defamation and privacy cases. Judge Chandna cited the Delhi High Court's decision in Rakesh Jagdish Kalra vs India Today Group (2024) as establishing the right to be forgotten in Indian jurisprudence. That case, which referenced the Supreme Court's landmark K.S. Puttaswamy vs Union of India privacy ruling from 2017, held that courts must balance competing rights between press freedom and individual privacy.

"The right to privacy is well recognized by the Supreme Court in the Constitution Bench judgment," according to the court order, which quoted the Delhi High Court's finding that the right to be forgotten and the right to be left alone constitute inherent aspects of privacy rights. The order determined that these privacy rights must take precedence when an individual has been exonerated of all allegations.

The court rejected arguments from news organizations that their reporting constituted fair journalism about public proceedings. Defendant publications argued that articles merely reproduced facts already in public domain and that freedom of press protections under Article 19(1) of the Indian Constitution should prevent content removal.

Hindustan Times' counsel asserted that impugned articles revealed nothing defamatory and merely reported judicial orders and proceedings. The Hindu's written statement claimed the newspaper published true reports about discharge proceedings and that this reporting would eventually establish inference of innocence favoring the plaintiff.

Several defendants raised limitation issues, arguing that defamation suits must be brought within one year of publication under Article 75 of the Limitation Act 1963. Indian Express noted that their challenged article was published on August 19, 2024, but the suit was not filed until October 6, 2025, exceeding the statutory period.

Google's counsel from Shruttima Ehensa argued that intermediaries should not be expected to police content online and that plaintiffs must provide specific URLs for court adjudication before intermediaries can act. The company also contended that the right to be forgotten is not currently recognized in Indian law, citing the Puttaswamy ruling's clarification that privacy rights are not absolute and must yield to competing interests including freedom of speech.

Judge Chandna found these arguments unpersuasive. The court determined that no case remained pending against Bhatnagar and that he stood completely exonerated by the discharge order. While acknowledging that the discharge order itself faced challenge before the Delhi High Court, the court noted that a subsequent order on July 24, 2025, dismissing the entire complaint was not shown to be under appeal.

"The permanence of digital information and easily accessible online records are causing potential harm to the plaintiff despite his exoneration from the case," according to the order. The court concluded that information serves no purpose other than detriment to Bhatnagar's reputation and that no public interest is served by keeping online information about an individual after criminal proceedings have ended with clearance of guilt.

The case differs from American defamation law in several respects. U.S. courts generally provide broad protections for truthful reporting about public proceedings, even when those proceedings result in acquittal or dismissal. The right to be forgotten, while recognized in European Union law through the Court of Justice's 2014 decision in Google Spain v AEDP, has not been adopted in U.S. jurisprudence.

The order establishes that all defendants must refrain from publishing, re-publishing, or circulating further content concerning the case until final disposal. News organizations must de-index, de-list, and de-reference the challenged URLs from their websites. Google and Indian Kanoon must block the URLs from being accessed through search engines.

Indian Kanoon later identified the case as relating to Moser Baer proceedings involving Bhatnagar's discharge, according to social media discussions. The legal database maintains extensive records of Indian court decisions and faced questions about whether court orders themselves should be subject to right-to-be-forgotten requests.

Judge Chandna's order noted that the plaintiff has a right to live with dignity and that articles published with his name cannot be allowed to perpetually remain on online platforms. "The right to live with dignity and to have peace of mind are integral to the right to life and liberty under the constitution," according to the decision.

The ruling affects publisher defendants including ANI Media Private Limited, IE Online Media Services Private Limited operating as Indian Express, The Printline Media Private Limited operating as The Print, HT Media Limited, Times Internet Limited, Bennett Coleman & Company Limited, New Delhi Television Limited, and THG Publishing Private Limited operating as The Hindu.

For marketing professionals and publishers, the case demonstrates increased judicial willingness to order content removal from search engines based on privacy claims following criminal exoneration. The order's impact extends beyond India's borders, as it requires global technology platforms to implement country-specific content filtering.

The procedural challenges revealed by the case highlight tensions between court-ordered content removal and transparency requirements. Website operators received removal notices without access to underlying court orders, creating compliance difficulties and limiting ability to mount legal challenges to delistings.

The case also raises questions about the scope of intermediary liability for search engines and legal databases. Google operates as an automated indexing service that does not create or host content, while Indian Kanoon provides access to public court records. The court's order requires both platforms to actively block access to third-party content based on privacy claims by individuals featured in that content.

Industry observers note that increased content removal orders could affect news archiving and legal research capabilities. Court decisions, once published, become part of public record documenting judicial reasoning and legal precedent. Removing access to these decisions, even when they favor criminal defendants, may limit transparency in judicial proceedings.

The November 10 order represents an interim measure preserving the subject matter of Bhatnagar's claims while legal issues are adjudicated. Judge Chandna stated that the expression would not bear finality on the case's merits, leaving open questions about permanent content removal versus temporary blocking during ongoing litigation.

Timeline

• August 22, 2023: Nitin Bhatnagar arrested by Enforcement Directorate in Moser Baer money laundering investigation
• March 14, 2024: Bhatnagar granted bail by Delhi court
• August 17, 2024: Bhatnagar discharged from money laundering case by Special Judge
• August 19, 2024: Multiple news organizations publish articles about discharge order
• July 24, 2025: Court dismisses entire complaint in underlying Moser Baer case
• October 6, 2025: Bhatnagar files civil suit seeking permanent injunction and damages against news organizations and technology platforms
• November 10, 2025: Principal District Judge Anju Bajaj Chandna orders Google and Indian Kanoon to de-index URLs related to criminal proceedings
• November 22, 2025: Google sends Search Console notifications to affected website owners
• November 26, 2025: Indian Kanoon states it was unaware of court order and Google refused to share order details
• Google reduces Search Console minimum thresholds enabling smaller sites to access performance data
• Google must disclose ad auction changes in transparency ruling
• Court clears path for private damages in Google ad tech cases

Summary

Who: Principal District and Sessions Judge Anju Bajaj Chandna ordered content removal affecting Nitin Bhatnagar, a banker discharged from money laundering allegations, along with defendants including Google LLC, Indian Kanoon, and nine Indian news organizations.

What: The court directed removal of approximately 60 URLs from search results and legal databases containing articles about Bhatnagar's arrest, prosecution, and discharge in an Enforcement Directorate money laundering case, citing right to privacy and protection of reputation following criminal exoneration.

When: The order was issued on November 10, 2025, affecting articles published primarily in August 2023 and August 2024, with Google sending removal notifications to website owners on November 22, 2025.

Where: The Patiala House Courts in New Delhi issued the order affecting search results visible in India through google.co.in, with implications for global content accessibility and legal database indexing.

Why: The court found that continued online availability of articles about criminal proceedings harmed Bhatnagar's professional reputation despite his complete exoneration, determining that privacy rights and the right to be forgotten outweighed freedom of press considerations when no public interest is served by maintaining information about resolved criminal cases where defendants were cleared of guilt.