Hdfc Life Insurance Company Limited vs Meta Platforms Inc. — Bombay HC (2025) — LawSathi Research

Hdfc Life Insurance Company Limited vs Meta Platforms Inc. — Bombay HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

Both Interim Application No.1108 of 2025 and Interim Application (Lodging) No.258 of 2025 disposed of by modifying and replacing the ad-interim order dated 29th November 2024 (described in the concluding paragraph as dated 24th November 2024): Defendant No.6 temporarily restrained from disclosing confidential information (Exhibit B-1) and from infringing/passing off 'HDFC Life' and 'Sar uthake jiyo'; Defendant Nos. 1 to 3 (Meta Platforms, WhatsApp LLC, Telegram) to remove/block identified accounts, groups, URLs and content upon intimation — as early as possible and in no case later than 36 hours per the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, conditioned on redacted screenshots, an undertaking and adequate identifiers; Defendant Nos. 4 and 5 to block domains/phone numbers/email addresses and instruct ISPs preferably within 24 hours; Defendant Nos. 1 to 3 to disclose basic subscriber information in a password-protected file; Registry to accept reply/rejoinder affidavits within two weeks.

Issue for consideration

Whether the ad-interim order dated 29th November 2024 (including the 24-hour timeline in paragraph No.18(vi)) should be vacated/modified, Defendant No.2 contending it is not in consonance with the 36-hour timeline prescribed under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. +1 more

Court's answer

In the peculiar facts and circumstances of the case, the ad-interim order dated 29th November 2024 could be modified and replaced by an order disposing of the plaintiff's application under Order XXXIX Rules (1) and (2) and Defendant No.2's application for modification.

Ratio / Principle

Underlying reasoning: a wide-ranging order was avoided because neither the plaintiff nor the intermediary can be adjudicators of infringing content; hence a tailored intimation-based mechanism was framed after detailed hearings.

Key takeaways

Both interim applications — Interim Application No.1108 of 2025 and Interim Application (Lodging) No.258 of 2025 — are disposed of in terms of the enumerated directions (clauses (a) to (j)).ratio¶37
Upon intimation by the Plaintiff, the actions required of Defendant Nos. 1 to 3 shall be taken as early as possible and in no case later than thirty-six hours, as prescribed under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code), 2021 — substituting the 36-hour statutory timeline for the earlier 24-hour direction in paragraph 18(vi) of the ad-interim order.ratio¶54

Detailed headnote1 paragraphs

Bombay High Court, Commercial Division (Manish Pitale, J.), 08.05.2025 — HDFC Life Insurance Co. Ltd. v. Meta Platforms Inc. & Ors.: The Court disposed of the Plaintiff's Interim Application No.1108 of 2025 (under Order XXXIX Rules (1) and (2)) together with Defendant No.2's (WhatsApp LLC's) Interim Application (Lodging) No.258 of 2025 in Commercial IP Suit No.177 of 2025 by modifying and replacing the ad-interim order dated 29.11.2024 (described in the concluding direction as dated 24.11.2024). Accepting the premise of Defendant No.2's objection that the earlier 24-hour takedown timeline was not in consonance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the Court directed that, upon intimation by the Plaintiff — supported by redacted screenshots, an undertaking and adequate identifiers (URLs/handles for Meta; phone numbers/invite links/administrator numbers for WhatsApp; phone/URL/account details for Telegram) — Defendants 1 to 3 (Meta Platforms, Inc., WhatsApp LLC, Telegram) shall remove, delete, block and disable offending accounts, groups, URLs and content as early as possible and in no case later than thirty-six hours. Defendant No.6 remains temporarily restrained from disclosing confidential information (Exhibit B-1) and from infringing or passing off 'HDFC Life' and 'Sar uthake jiyo'. Defendants 1–3 must disclose basic subscriber information (incl. IP details) in a password-protected file; Defendants 4–5 must instruct ISPs preferably within 24 hours. The order is expressly not a precedent; pleadings to be completed within two weeks.