The Delhi High Court recently dismissed a defamation suit filed by Addictive Learning Technology Limited (Addictive Learning) seeking a permanent injunction and damages over tweets posted by defendants Aditya Garg and others on the social media platform ‘X’ (formerly Twitter).

Justice Manmeet Pritam Singh Arora, while ruling on the case, observed that "X as a social media platform is dynamic and interactive, and a single impugned tweet should not be considered in isolation to determine its defamatory nature."

Addictive Learning contended that the defendants’ tweets harmed its reputation, financial stability, and stock value. The company sought a permanent injunction to restrain further posts and demanded damages. However, Defendant No. 2 challenged the suit, arguing that there was no cause of action against him since Impugned Tweet No. 4 did not reference Plaintiff No. 1. He maintained that his statement was an honest opinion based on professional experience and further alleged that Plaintiff No. 2 frequently resorted to litigation to suppress criticism.

The court noted that the cause of action against defendants 1, 2, 4, and 5 was distinct and unrelated. The controversy originated from Plaintiff No. 2’s Lead Tweet, which criticized National Law Universities (NLUs) and questioned the competence of their graduates recruited through campus placements. The responses from Defendants 1 and 2, both NLU alumni, led to separate conversation threads.

The court assessed whether these tweets fell under the category of "Online Trolling" as defined in a Sage Publications study, which described trolling as a strategy to provoke emotional reactions and drive social media engagement. Plaintiff No. 2 initially engaged in the discussions and appeared to enjoy the interactions but later deemed the responses defamatory when the exchanges escalated. The court concluded that the tweets exhibited characteristics of both proactive and reactive trolling.

Examining defamation under Section 499 of the Indian Penal Code (IPC) and the corresponding Section 356 of the Bhartiya Nyaya Sanhita, 2023 (BNS), the court relied on the precedent set in Nidhi Bhatnagar v Citi Bank N.A. It distinguished between statements that merely hurt feelings and those that genuinely harm an individual’s reputation. The court held that for a valid defamation claim, the plaintiff must prove that the defendant’s words significantly damaged their social standing.

Furthermore, the court highlighted the legal recourse available under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (IT Rules 2021). Under these rules, social media users can seek redress against defamatory content by filing a complaint with the platform’s Grievance Officer, with the option to appeal before the Grievance Appellate Committee. The plaintiffs, however, did not pursue this statutory remedy before filing the suit on July 12, 2024.

The court emphasized that social media defamation could not be equated with defamation in traditional media such as newspapers and magazines. It noted that users of ‘X’ generally do not treat it as a verified or serious source of information. Unlike newspapers, which are relied upon for forming opinions, social media posts are often casual and fleeting.

“In the case of newspapers and magazines, readers attach seriousness to the content and rely on it for information. In contrast, the casual medium of ‘X’ is not perceived by its users as a reliable or verified source of information,” the court observed.

The court determined that the tweets in question were reactionary rather than defamatory. It found no direct legal injury and concluded that the defamation test was not satisfied. The plaintiffs’ delay in filing the suit further suggested they did not initially perceive the tweets as defamatory.

Consequently, the court ruled that Impugned Tweet Nos. 1 to 6 did not amount to defamation, as they stemmed from deliberate provocation by Plaintiff No. 2. The court distinguished between defamation and vulgar abuse, acknowledging the conversational nature of social media interactions. It also held that plaintiffs failed to establish substantial injury and fully disclose all conversation threads in support of their claim.

Dismissing the suit, the court imposed costs of ₹1,00,000 on the plaintiffs, payable to the Delhi High Court Legal Services Committee within four weeks.

For Plaintiff: Advocate Raghav Awasthi
For Defendant No. 2: Advocates Himanshu Bhushan and Shagun Srivastava
Case Title: Addictive Learning Technology Limited v Aditya Garg (2025:DHC:1178)