he Delhi High Court dismissed a defamation lawsuit filed by Addictive Learning Technology Limited (plaintiff) against individuals who posted critical tweets on X (formerly Twitter). The court emphasized that tweets within a conversational thread cannot be analyzed in isolation to determine defamation, stressing the casual and reactive nature of social media interactions.
Case Background
The plaintiffs alleged that four defendants posted “harmful and derogatory” tweets on X, damaging their reputation. The tweets originated from two conversation threads sparked by a “Lead Tweet” posted by the second plaintiff, discussing trends in legal education and National Law Universities (NLUs). The defendants, NLU alumni, responded critically, leading to a heated exchange.
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The court rejected the plaint under Order VII Rule 11(a) of the CPC, citing a lack of actionable defamation and failure to disclose cause of action.
1. Conversational Nature of X Requires Holistic Analysis
Justice Manmeet Pritam Singh Arora highlighted that social media posts are fast-paced and informal, making isolated assessments impractical. The court noted:
“The absorption by the reader and the reaction to the post is impressionistic and fleeting… An elaborate analysis of a tweet may be disproportional.”
The judgment referenced UK’s Stocker v. Stocker and Monroe v. Hopkins cases, which stress that tweets must be interpreted as a casual reader would perceive them within the entire thread.
2. Statutory Remedies Under IT Rules 2021 Ignored
The plaintiffs failed to utilize grievance redressal mechanisms under the IT Rules 2021, which allow users to report defamatory content to platform intermediaries. Justice Arora remarked:
“The plaintiffs’ inaction in approaching the Grievance Officer indicates they did not perceive immediate harm, weakening their claim.”
3. Opinions ≠ Defamation Without Proven Harm
Citing Kaushal Kishore v. State of U.P., the court reiterated that holding an opinion isn’t defamatory unless it causes tangible harm. The plaintiffs could not prove reputational damage or financial loss. The judgment stated:
“Substantial injury must be established… Mere insults or heated exchanges on social media don’t suffice.”
4. Provocative Tweets Invite Reactions
The plaintiffs’ Lead Tweet criticized NLUs, calling them “rent-seeking organizations” with unemployable graduates. The court observed that provocative posts invite counter-criticism, and users must “have broad shoulders to bear the backlash.”
5. Anonymous and Vulgar Posts Lack Defamatory Weight
Tweets from anonymous users (Defendants 4 and 5) were deemed “vulgar abuse” rather than defamation. The court cited Vine v. Barton, noting that insults in “heat of passion” don’t lower reputation in the eyes of reasonable readers.
Principles Laid Down by the Court
- Full Disclosure of Conversation Threads: Plaintiffs must present entire threads, including their own tweets, to avoid one-sided claims.
- No Action for “Mere Abuse”: Insults without tangible harm aren’t actionable.
- Use of Statutory Remedies: Aggrieved parties should first approach platform grievance officers.
- Context Over Isolation: Tweets must be read as part of dynamic, interactive exchanges.
The Delhi High Court’s decision underscores the nuanced approach required for defamation claims on social media. By dismissing the plaint with ₹1 lakh costs
Justice Arora concluded:
“A plaintiff alleging defamation must approach the court with clean hands, disclosing full context and avoiding cherry-picked grievances.”
Title: ADDICTIVE LEARNING TECHNOLOGY LIMITED & ANR v. ADITYA GARG & ORS
