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2026 Supreme(Mad) 654

IN THE HIGH COURT OF JUDICATURE AT MADRAS
N.SENTHILKUMAR, J.
T. Rangaraj – Appellant
Versus
Joy Crizildaa – Respondent
O.A. No. 948 of 2025, Appeal No. 4798 of 2025, C.S. (Comm. Div.) No. 250 of 2025
Decided On : 07-01-2026

Advocates Appeared:
For the Appellants : Srinath Sridevan, Vijayan Subramanian
For the Respondents: S. Prabhakaran, R. Sudha

Interim injunctions in defamation suits must balance free speech and reputation, requiring clear evidence of harm; mere allegations are insufficient for relief.

Headnote:(A) Commercial Courts Act, 2015 - Sections 2(1)(c)(xvii) and 12A - Defamation through social media - The application for interim injunction sought to restrain the defendant from making false and defamatory statements against the plaintiff which impair his reputation and goodwill in hospitality and entertainment sectors - The plaintiff claimed irreparable commercial loss due to the defendant's actions; however, the court found no merit due to failure to establish prima facie case or commercial exploitation - Plaintiff's relationship with defendant under scrutiny; allegations of marriage were disputed - The court highlighted the need for careful consideration of freedom of speech and rights to privacy, stating that interim injunctions in defamation cases are not readily granted unless harm is clear and unambiguous - Both applications dismissed. (Paras 2-4, 48, 49)

(B) Defamation - Standards for interim injunctions - Caution required in granting ex parte injunctions in defamation suits; the fundamental right to free speech must be balanced against reputational rights, requiring a clear showing of irreparable harm or a prima facie case. (Paras 5-9)

(C) Rights of Public Figures - The essence of a public figure’s rights concerning reputation and privacy—public figures must navigate the space between personal life disclosures and the limitations of privacy. (Paras 18-20)

Table of Content
1. applicant's efforts in hospitality and public recognition (Para 2 , 3 , 4 , 5)
2. defamatory actions impact on reputation and business (Para 6 , 7 , 8 , 9 , 10)
3. arguments from first defendant regarding shared relationship and marriage (Para 12 , 13 , 14 , 15 , 16)
4. hearing on defamation and requirements for injunction (Para 18 , 19 , 20)
5. substantial evidence showcasing marital relationship (Para 21 , 22 , 23 , 24 , 25 , 26)
6. objections raised by the plaintiff against the first defendant (Para 27 , 28 , 29 , 30)
7. implications of social media speech and public interest (Para 39 , 40 , 41)
8. final dismissal of plaintiff's applications (Para 48 , 49)

ORDER :

1. It is relevant to quote the sacred couplet No.144 of Thiruvalluvar:

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.

2. The applicant/plaintiff has filed the above suit for the following reliefs:

a) Permanent injunction restraining the 1st defendant, her men, agents, representatives or any persons claiming under or through her, from in any manner making, writing, uploading, printing, publishing, broadcasting, distributing, posting, circulating, or disseminating in any form of media, whether print, electronic, digital, internet, social media platforms or otherwise, any false, malicious or defamatory material, statements, videos, reels, captions, photographs, audio-visual content of communications disparaging the applicant's/plaintiff's personality rights, which directly or indirectly defame his character, personal life, professional standing or reputation in the hospitality industry, entertainment sector or the public domain, thereby causing him irreparable commercial loss and goodwill and reputation;

b) A mandatory injunction directing the 1st defendant to remove/delete the false, defamatory instagram post made in her Instagram profile published on 26.07.2025, 27.07.2025, 30.07.2025, 19.08.2025, 31.08.2025 and remove/delete any other material or statements aforesaid including tagging the name of the plaintiff in all online media including but not limied to X(twitter), Facebook, Telegram, Instagram.

Brief facts of the case of the Applicant is as follows:

3. The applicant/plaintiff is one of the directors in Madhampatty Thangavelu Hospitality Private Limited, which was incorporated on 30.08.2010, which deals with catering, and food services since 2010 under the brand name "MADHAMPATTY PAKASHALA" with sheer commitment towards their business, the company where the plaintiff was one of the directors, had grown to a greater extent and the plaintiff had taken part in business accomplishments. He has also ventured into the field of cinema and television. 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 was also taking part in a popular TV reality show "Cooku with Comali" Season 5 (2024) where his culinary expertise won him appreciation in the said show.

4. These ventures have reinforced the standing of the applicant as not only a successful businessman but also a well-recognized public personality. The applicant's success story was featured in Vijay Television's Mudhal Vanakkam show as "Madhampatty Rangaraj's Secret of Success" on May, 2024. The applicant has received several awards and they were also conferred with Asia's Most Admired Hospitality Professional Award and had gathered huge reputation and goodwill across the country.

5. According to the applicant/plaintiff, the first respondent/first 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. The plaintiff had reposed trust in her and extended friendship in good faith without knowing the 1st defendant’s ulterior motives. As days rolled on, the professional association

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