The court resolved a dispute over intermediary liability and trade mark infringement on a review platform via an undertaking, allowing the platform to host reviews while establishing a mechanism for removing fake or confidential content, while leaving the legal status of the platform as an 'intermediary' open.

MANMEET PRITAM SINGH ARORA, J.

(ORAL)

1. The present appeal has been filed by the Appellant against the order dated 15.01.2026 [‘impugned order’] wherein the District Judge (Commercial Court) - 06, South East, Saket Courts, Delhi, has allowed the Respondent’s application under Order XXXIX Rule 1 & 2 CPC read with Section 151 of the Code of Civil Procedure, 1908 (CPC), in the matter titled SynapseIndia Outsourcing Pvt. Ltd. & Anr. v. Info Edge (India) Ltd. CS(COMM) NO. 728/ 2025. The relevant portion of the interim injunction granted reads as under:

“29. Consequently, till further orders, an ad-interim order of injunction is passed in favour of the Plaintiffs and against the Defendant restraining Defendant from using the trade name of the Plaintiff No.1 i.e. "SynapseIndia" and "Synapselndia I.T. Outsourcing @ Peace of Mind" on its web-portal i.e. www.ambitionbox.com for inviting/permitting users to post reviews about its work culture or otherwise in respect or in relation to the Plaintiffs. Time of 72 hours from today is given to the Defendant for ensuring compliance of the said direction.

30. Further, Plaintiffs are at liberty to file application to the Defendant and/or to the Defendant through Counsel for removal of the comments /posts on the platform of Defendant mentioning the details of the same and Defendant is directed to remove the same within 36 hours of receiving the said application from the Plaintiffs.”

2. The impugned order was passed in a suit, wherein the Respondents alleged trade mark and copyright infringement, passing off and defamation on account of certain negative reviews posted by users on the Appellant’s platform ‘AmbitionBox’. The Respondents stated that the Appellant created a page on its platform enabling users to post reviews about the Respondents’ company without their express permission, and thus used their trade mark without prior authorisation. It was the stand of the Respondent that Appellant’s platform permitted posting of reviews without verification if the ‘user, posting the specific content, had actually worked with the company or not. It was contended that the objected to, negative reviews were ex-facie fake and were causing damage to the goodwill and reputation of the Respondent/plaintiffs.

3. However, it is the stand of the Appellant that the Appellant provides a neutral online platform i.e. www.ambitionbox.com, that permits its registered users to post company reviews and salary insights etc. It is a user- driven platform which hosts third-party content in the form of reviews and ratings, and serves as an important source of information for job seekers to evaluate the work culture, compensation etc. at prospective employer organisation. The Appellant neither initiates, authors, edits, selects the receiver of, modifies nor endorses such content.

3.1. It is stated that the platform of the Appellant does not exercise editorial control over ‘user’ reviews. It publishes and informs the users about its Community Guidelines, Terms of Use and Privacy Policy. Further, the Appellant has a multi-tier content review mechanism to take down any content which does not adhere to its Community Guidelines.

3.2. It is stated that the Impugned Order effectively compels the Appellant to apply its own mind to whether the content on its platform should or should not be blocked, proactively screen user content, and publish only “bonafide, identified and factual reviews”.

3.3. It is contended that anonymity on the Appellant’s platform is designed to protect free speech of employees against employers. It is because of this model that several users feel comfortable in speaking up, sometimes to highlight inter alia workplace harassment, favouritism, biasness or pay disparity etc. It is stated that the Trial Court has failed to recognise the fundamental right to free speech of users of the platform. The directions operate as a pre-trial gag order, curtailing speech and criticis