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Right to Be Forgotten: Bombay HC Orders Petitioner’s Identity Masked From Online Court Records

Shivam Y.

The Bombay High Court directed that a petitioner's identity be masked from digital court records, holding that the right to privacy includes the right to be forgotten after criminal proceedings are quashed. - ABC v. State of Maharashtra & Ors.

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Right to Be Forgotten: Bombay HC Orders Petitioner’s Identity Masked From Online Court Records
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The Nagpur Bench of the Bombay High Court has reaffirmed the importance of the constitutional right to privacy by directing that the identity of a petitioner be masked from publicly accessible court records after criminal proceedings against him had already been quashed. The Division Bench held that continued online availability of his personal details served no public purpose and unfairly affected his reputation and professional life.

Background of the Case

The petitioner, identified only as ABC in the judgment, had been named in an FIR registered in 2017 at Bajaj Nagar Police Station, Nagpur. During the investigation, the parties settled their dispute amicably, following which the Bombay High Court quashed the FIR and all subsequent criminal proceedings.

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Despite the case ending years earlier, the petitioner argued that unredacted digital copies of court records remained available online and were easily accessible through search engines. According to him, these records continued to surface during background checks, causing prejudice to his career, social standing, and family.

The Bench of Justice Urmila Joshi-Phalke and Justice Nivedita P. Mehta observed that the right to privacy, guaranteed under Article 21 of the Constitution, includes the right to be forgotten.

The court noted,

“While the access to information is a fundamental aspect of democracy, the same cannot be divorced from the need to balance the right to information of the public with the individual’s right to privacy.”

It further observed that once criminal proceedings have been quashed and no public interest remains, retaining personal details on publicly accessible digital platforms is unjustified.

The Bench also referred to earlier decisions of the Bombay High Court and the Delhi High Court recognising that courts must balance transparency with an individual's privacy rights in appropriate cases.

Allowing the petition, the High Court directed its Registry to remove the petitioner's name from the digital records and search results relating to the concerned criminal proceedings.

It further ordered that, in all future references to those cases, the petitioner should be identified only as "ABC" instead of by name.

The rule was made absolute.

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Case Details

Case Title: ABC v. State of Maharashtra & Ors.

Case Number: Criminal Writ Petition No. 470 of 2026

Judge: Justice Urmila Joshi-Phalke and Justice Nivedita P. Mehta

Decision Date: 03 July 2026

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