Synopsis

The plaintiffs filed a contempt application against Google India and Google LLC, alleging willful disobedience of earlier judgments that directed the defendants to investigate complaints regarding use of the plaintiffs' trademarks as keywords. The plaintiffs contended that the defendants were also obligated to proactively prevent use of the trademarks in Ad-Text, Ad-Title, and URLs without any complaint being filed. The High Court dismissed the contempt application, holding that: (i) the directions in the judgments were confined to use of trademarks as keywords, not Ad-Text/Ad-Title/URL; (ii) the plaintiffs had confined their submissions to the keyword issue based on the defendants' statement that they would not permit trademark use in Ad-Text/Ad-Title under their policy; (iii) contempt jurisdiction cannot be used to expand or reinterpret court orders; (iv) where two interpretations are possible, contempt proceedings are not maintainable.

1. Heading of the judgment

High court of delhi at new delhi

Cs(comm) no. 1 of 2017 with i.a. no. 18605 of 2025

M/s drs logistics (p) ltd & anr. (plaintiffs) vs. Google india pvt ltd & anr. (defendants)

Coram: hon’ble mr. justice tejas karia

Core Law: Contempt of Courts Act, 1971 – Section 12 – Order XXXIX Rule 2A CPC – Willful disobedience of court orders – Interpretation of directions – Scope of contempt jurisdiction – Trademark use as keywords vs. Ad-Text/Ad-Title/URL.

Court: High Court of Delhi at New Delhi
Coram: Hon’ble Mr. Justice Tejas Karia (Single Judge)
Date of Judgment: June 15, 2026 (Reserved on December 23, 2025)
Case No.: CS(COMM) 1/2017 with I.A. No. 18605/2025
Citation: 2026:DHC:5102

2. Legal framework

Major laws and provisions involved:

• Contempt of Courts Act, 1971 – Section 12 (punishment for contempt)

• Code of Civil Procedure, 1908 – Order XXXIX Rule 2A (consequences of disobedience of injunction), Section 151 (inherent powers)

• Trade Marks Act, 1999 – Sections 29, 30 (infringement of trademark)

• Google AdWords Trademark Policy

Subject matter of the judgment:

Whether Google India and Google LLC have willfully disobeyed court judgments directing them to investigate complaints regarding use of trademarks as keywords, by allegedly permitting third parties to use the trademarks in Ad-Text, Ad-Title, and URLs without the plaintiffs lodging any specific complaint, and whether the court's directions extended to proactive monitoring of such use.

Key legal principles applied:

• Scope of contempt jurisdiction is narrow:&

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