A Delhi court has rejected a defamation suit filed by advocate Vikram Singh Chauhan against Google India and several media organisations over news reports and online content relating to the 2016 Patiala House Court incident. The court held that the suit, filed in 2023, was barred by the law of limitation because the publications being challenged dated back to 2016 and no fresh publication within the limitation period had been shown.
Background of the Case
Vikram Singh Chauhan approached the court seeking a permanent injunction, removal of allegedly defamatory news reports, written apologies, and symbolic damages of Re. 1. He claimed that media organisations had wrongly portrayed him following incidents that took place at Patiala House Courts in February 2016 during proceedings involving JNU-related events.
According to the plaint, the reports and television debates described him using derogatory expressions and allegedly harmed his professional reputation. Chauhan also claimed that in 2022 a prospective client declined to engage him after finding the online material and that he suffered reputational damage during elections for the Honorary Secretary post of the New Delhi Bar Association.
Several defendants responded by filing applications under Order VII Rule 11 of the Civil Procedure Code (CPC), arguing that the suit deserved to be rejected because it had been filed beyond the prescribed limitation period and did not disclose a legally sustainable cause of action.
Court's Observation
Senior Civil Judge-cum-Rent Controller Shruti Chaudhary observed that while deciding an application under Order VII Rule 11 CPC, the court is required to examine only the plaint and the documents relied upon by the plaintiff.
The court found that the publications complained of were admittedly made in February 2016, whereas the suit was instituted only in 2023. It noted that the plaint did not allege that the defendants had republished or recirculated the material within the statutory limitation period prescribed for defamation claims.
Addressing the plaintiff's reliance on Google and YouTube search results, the court clarified that continued online accessibility of old material does not automatically amount to a fresh publication.
As the court observed,
“The mere availability or discoverability of such material on the internet does not, by itself, amount to a republication or recirculation so as to give rise to a fresh cause of action each time the said material is accessed.”
The court further remarked that there is “a difference between continuing damage from a wrong already done and commission of a fresh wrongful act.”
Since no specific instance of fresh publication within the limitation period had been pleaded, the plaint disclosed only the continuing consequences of earlier publications rather than a new cause of action.
Decision
Holding that the suit was ex facie barred by limitation, the court rejected the plaint under Order VII Rule 11(d) CPC. Having reached that conclusion, it found it unnecessary to examine the defendants' remaining objections.
The court consequently allowed the applications seeking rejection of the plaint, dismissed the remaining pending applications as infructuous, disposed of all other pending applications, and directed that there would be no order as to costs.
Case Details
Case Title: Vikram Singh Chauhan v. Google India & Ors.
Case Number: CS SCJ 283/23
Judge: Ms. Shruti Chaudhary, Senior Civil Judge-cum-Rent Controller, Patiala House Courts, New Delhi
Decision Date: 14 July 2026
