Venkata Aswini Reddy Koyya @ Ashu Reddy vs Yenumula Satyanarayana Murthy

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2026 Supreme(Telangana) 308

IN THE HIGH COURT FOR THE STATE OF TELANGANA: HYDERABAD
P. SAM KOSHY, J.
Ms.Venkata Aswini Reddy Koyya @ Ashu Reddy - Petitioner
Versus
Mr. Yenumula Satyanarayana Murthy and others – Respondents
Civil Revision Petition No.1346 of 2026
Decided On : 29-04-2026

Important Points

The right to privacy and reputation under Article 21 of the Constitution can necessitate interim restraint on freedom of speech under Article 19(1)(a) when publications are prima facie defamatory and likely to cause irreversible harm to an individual's dignity and livelihood.

Subject

Civil Law - Injunction and Defamation

Act Referred

CONSTITUTION OF INDIA : Art.21, Art.227
CIVIL PROCEDURE CODE : O.7 R.1, O.7 R.2, S.26, S.39(1), S.39(2)

Headnote

The petitioner approached the Court under Article 227 of the Constitution of India challenging a Trial Court order that declined ex parte ad interim injunction in a suit filed under Section 26 read with Order VII Rule 1 and 2 of the Civil Procedure Code, 1908. The petitioner, a professional actress, sought to restrain respondents from publishing defamatory content across various media platforms including YouTube and social media that denigrated her character in connection with F.I.R.No.78 of 2026. The primary issue was whether the right to privacy and reputation under Article 21 of the Constitution outweighs the freedom of speech and expression under Article 19(1)(a) in cases of prima facie defamatory content. The Court reasoned that while freedom of speech is a cherished value, it is subject to reasonable restrictions under Article 19(2), and in instances where content is sensational and harmful to dignity and livelihood, the balance of convenience tilts toward protecting the individual's privacy until the merits are adjudicated. With these observations, the Civil Revision Petition stands allowed.

Advocates Appeared:
For the Petitioner: Mr. V. Murali Mohan

Table of Content
1. procedural history of the suit and application for temporary injunction against defamatory content. (Para 3 , 4 , 5 , 6 , 7)
2. impact of defamatory digital content on professional reputation and livelihood. (Para 8 , 9)
3. balancing the right to privacy (art 21) against freedom of speech (art 19). (Para 10 , 11 , 12)
4. necessity of interim restraint to prevent irreversible harm pending trial court decision. (Para 13 , 14 , 15 , 16)

ORDER :

P. SAM KOSHY, J.

1. The instant Civil Revision Petition has been filed by the petitioner under Article 227 of the Constitution of India assailing the order dated 28.04.2026 in I.A.No.576 of 2026 in O.S.No.176 of 2026 passed by the XI Additional Chief Judge, City Civil Court, at Hyderabad, insofar as the Trial Court declined to grant ex parte ad interim injunction notwithstanding the urgency demonstrated on the face of affidavit and material on record, (for short, ‘the impugned order’).

2. Heard Mr. V. Murali Mohan, learned counsel for the petitioner.

3. Vide the impugned order, the Trial Court directed issuance of summons to the respondents and posted the matter on 06.07.2026.

4. The petitioner filed the above suit, viz., O.S.No.176 of 2026 under Section 26 read with Order VII Rule 1 and 2 of Civil Procedure Code, 1908 seeking for mandatory and perpetual injunction by restraining defendant Nos.2 to 31, their respective agents, employees, servants, representatives and successors from further publishing, uploading, telecasting, sharing or in any manner disseminating any video, image, article, headline, caption, etc., on the on-line video sharing platforms, websites, YouTube Channels, social media handles, television Channels, newspapers or any other medium whatsoever, which defames, imputes or denigrates the petitioner herein.

5. Along with the said suit, the petitioner has filed I.A.No.576 of 2026 under Section 39(1) and (2) of Civil Procedure Code, 1908 praying the Trial Court for a temporary injunction by restraining respondent No.1, his successor, agents, representatives to forthwith take down, withdraw, cause to be retracted and to not further publish or exhibit any defamatory complaint, statement, allegation, narrative, interview, byte, post or communication uttered, made, supplied or caused to be supplied by respondent No.1 or on his behalf to respondent Nos.2 to 31 or to any other person or platform whatsoever against the petitioner in connection with F.I.R.No.78 of 2026, dated 20.04.2026; and to injunct respondent Nos.2 to 31 by ordering take down of already published defamatory complaint, statement, allegation, narrative, interview, byte, post or communication.

6. On 28.04.2026, the Trial Court passed the following order, viz.,

“Issue summons to the defendant; for appearance, call on 06.07.2026; I.A.No.576 of 2026 – Heard, the learned counsel for petitioner / plaintiff. Perused the material available on record. However, circumstances stated in the petition affidavit as the reason mentioned this Court deem it just and necessary to issue urgent notice to the respondents returnable by 06.05.2026.”

7. Perusal of the above order would show that the Trial Court has given a short date for the petitioner / plaintiff to serve notice on the respondents and adjourned the matter to 06.07.2026 for taking up I.A.No.576 of 2026 which is an application filed under Section 39(1) and (2) of Code of Civil Procedure, 1908 seeking for temporary injunction.

8. Learned counsel for the petitioner submitted that petitioner herein is an actress in the film industry and earns her own living from assignments in various films, web series, television shows, brand and public relations associations, marketing campaigns and life engagements.

9. Learned counsel for the petitioner, meanwhile referring to the contents that are reflected in the above suit starting from paragraph No.9 onwards of the suit which are clippings from various websites, television channels and also videos uploaded in the YouTube and other