Allahabad High Court Strengthens Bench, Clarifies Intermediary Liability in Shaadi.com Case

ALLAHABAD, INDIA – The Allahabad High Court witnessed a significant weekend, marked by a substantial enhancement of its judicial strength and a crucial ruling that reinforces the safe harbor protections for online intermediaries. The court welcomed 24 new judges, bringing its working strength to 110, while simultaneously delivering a judgment that quashed a criminal FIR against Shaadi.com CEO Anupam Mittal, underscoring the nuanced application of intermediary liability under the Information Technology Act, 2000.

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Twenty-Four New Judges Take Oath, Boosting Court's Strength

On Saturday, September 27, 2025, the Allahabad High Court, one of the nation's largest and most burdened judiciaries, administered the oath of office to 24 newly appointed judges. The ceremony saw 10 advocates from the Bar and 14 judicial officers from the subordinate judiciary elevated to the High Court bench, a move aimed at alleviating the court's massive case backlog.

The appointments were notified by the Central Government on Friday, September 26, following a recommendation from the Supreme Court Collegium on September 2. The Collegium had initially proposed the names of 12 advocates and 14 judicial officers. However, the government's final notification withheld the names of two advocates, a point of continuing discussion within legal circles regarding the dynamics of judicial appointments.

With these new appointments, the working strength of the Allahabad High Court has risen to 110 judges, including the Chief Justice. While this is a welcome development, the court still operates at a significant deficit against its sanctioned strength of 160 judges. The legal community hopes this infusion of new judicial talent will expedite the disposal of cases and enhance access to justice in the state.

The newly appointed judges from the Bar are: - Vivek Saran - Vivek Kumar Singh - Garima Prashad - Sudhanshu Chauhan - Abdhesh Kumar Chaudhary - Swarupama Chaturvedi - Siddharth Nandan - Kunal Ravi Singh - Indrajeet Shukla - Satya Veer Singh

The new judges elevated from the judicial service include: - Dr. Ajay Kumar-II - Chawan Prakash - Divesh Chandra Samant - Prashant Mishra-I - Tarun Saxena - Rajeev Bharti - Padam Narain Mishra - Lakshmi Kant Shukla - Jai Prakash Tiwari - Devendra Singh-I - Sanjiv Kumar - Vani Ranjan Agrawal - Achal Sachdev - Babita Rani

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High Court Quashes FIR Against Shaadi.com CEO, Reaffirms Section 79 Protections

In a legally significant ruling with wide-ranging implications for online platforms and corporate executives, a division bench of the Allahabad High Court quashed a First Information Report (FIR) filed against Anupam Mittal, the CEO of the matrimonial service Shaadi.com. The bench, comprising Justice Siddhartha Varma and Justice Madan Pal Singh, held that as an intermediary, the platform is protected under Section 79 of the IT Act, and its CEO cannot be held personally liable for the actions of third-party users.

Background of the Case

The case originated from a complaint by a user of Shaadi.com, a lawyer, who alleged he was being harassed and blackmailed by another user on the platform. The informant claimed that despite his complaints to customer care and directly to Mr. Mittal, no effective action was taken to remove profiles engaging in obscenity. Consequently, he filed an FIR against the CEO under several sections of the Indian Penal Code, including 420 (Cheating), 384 (Extortion), 507 (Criminal intimidation by an anonymous communication), and 120-B (Criminal Conspiracy), along with Section 67 of the Information Technology Act.

Mr. Mittal challenged the FIR by filing a writ petition before the High Court, seeking its quashing. His counsel, Senior Advocate Mr. Manish Tiwary, argued that the CEO could not be personally implicated and that the company, as an intermediary, had statutory protection.

The Court's Analysis and Ruling

The High Court's judgment meticulously dissects the principles of intermediary liability and the personal culpability of corporate officers. The bench made several key observations that formed the basis of its decision.

1. No Personal Liability for the CEO: The court was unequivocal in its finding that the allegations did not constitute an offense committed by Mr. Mittal in his personal capacity. The bench observed, “The petitioner Anupam Mittal could not be alleged to have committed any offence in his personal capacity.” This distinction is critical in corporate criminal law, preventing the automatic attribution of liability to a company's leadership for platform-related issues without evidence of direct involvement or mens rea.

2. The Protection of Section 79 of the IT Act: Central to the court's reasoning was the application of Section 79 of the IT Act, which provides a "safe harbor" for intermediaries. This provision exempts intermediaries from liability for any third-party information, data, or communication link made available or hosted by them, provided they meet certain due diligence requirements.

Relying on the precedent set by the Supreme Court in Google India Private Limited vs. Visaka Industries , the High Court held that Shaadi.com functioned as an intermediary or facilitator. As such, it was not responsible for the content generated or actions performed by its users. The court noted that the company had taken action when complaints were received, evidenced by the deletion of one of the profiles the informant had complained about. The judgment stated:

“As and when complaints were received actions were definitely taken and we also definitely find that the intermediary i.e. the company of which the petitioner was a Chief Executive Officer had the protection of Section 79 (1) and (2) of the IT Act and there was definitely no abetment from the side of the company which was running the platform.”

3. User's Choice and Agency: The court also highlighted the user's own agency in the matter. It pointed out that the informant, despite the alleged harassment, had continued to use the platform. “Also, despite the harassment he had continued with the platform. He could have easily withdrawn from the platform,” the bench observed. This observation suggests that when a user has a clear and simple recourse—such as ceasing to use a service—it may weaken claims of being a helpless victim of the platform itself, particularly when the harm is perpetrated by another user.

4. No Prima Facie Case for IPC Offences: Ultimately, the court concluded that the essential ingredients for the alleged IPC offenses were not met. It held that no case for extortion or cheating was made out against the petitioner. By quashing the FIR, the court prevented the initiation of a criminal prosecution it deemed to be an abuse of the process of law.

Legal Implications

This judgment serves as a vital reiteration of the intermediary liability framework in India. For legal professionals advising technology companies, online marketplaces, and social media platforms, this ruling reinforces several key takeaways: - The Corporate Veil: The decision helps protect corporate executives from frivolous or vexatious litigation targeting them personally for user-generated content issues. - Importance of Due Diligence: While the platform was protected, the court did note that "actions were definitely taken" on complaints. This underscores the importance for intermediaries to have robust notice-and-takedown mechanisms and to act upon legitimate complaints to maintain their safe harbor protection under Section 79. - Guidance for Litigants: The ruling provides clarity for potential litigants, guiding them to focus on the actual perpetrators of online harassment rather than the platforms that merely host the content, unless they can demonstrate that the intermediary failed in its statutory duties.

As the Allahabad High Court begins a new chapter with its newly strengthened bench, this landmark decision on intermediary liability sets a clear and pragmatic precedent, balancing user protection with the operational realities of the digital economy.