Ms Getmyuni Education Services Private Limited vs Mangalayatan University & Anr 2026 DHC 1394

Synopsis

This Delhi High Court judgment allows two appeals filed by an education technology platform against interim injunction orders that restrained it from displaying information about two universities on its website. The appellant, Getmyuni Education Services, operates a website providing comprehensive information about universities and colleges in India, including rankings derived from public sources such as NIRF, 'The Week', and 'India Today'. The respondent universities filed suits seeking permanent and mandatory injunctions, alleging that the manner of display on the appellant's website was disparaging to their reputation. The Trial Court granted interim injunctions restraining the appellant from using the universities' names and details. The High Court set aside these orders, holding that the appellant has the right to use publicly available information as long as it is not presented in a disparaging manner, and that the respondents failed to make out a prima facie case for injunction.

1. Case Identification & Coram

Citation: 2026:DHC:1394

Court: High Court of Delhi at New Delhi

Jurisdiction: Civil Appellate Jurisdiction

FAO Nos.: 126/2023 and 129/2023

Coram: Hon'ble Justice Manoj Kumar Ohri

Nature of Bench: Single Judge

Date of Pronouncement: 17th February 2026

Date of Reservation: 10th February 2026

2. Legal Framework & Relevant Provisions
The judgment engages with intellectual property law and civil procedure:

• Substantive Law:
  Copyright Act, 1957: The appellant claimed exception under this Act for displaying extracts from publicly available data.
  Trade Marks Act, 1999: The appellant claimed exception under this Act for using names/information without misrepresentation or claiming association.

• Procedural Law:
  Code of Civil Procedure, 1908, Order 39 Rules 1 and 2: Provisions governing grant of temporary injunctions. The Trial Court had allowed applications under these provisions.
  Section 96 CPC: Appeals from original decrees (framework for appeals against interim orders).

• Intellectual Property Principles:
  Right to use publicly available information.
  Protection against disparagement of reputation.
  No appropriation of intellectual property or passing off without misrepresentation.
  Right to be forgotten/right to seek removal of information from search results.

• Other Relevant Concepts:
  National Institutional Ranking Framework (NIRF) rankings – public domain information.
  Role of education technology (EdTech) platforms as aggregators of information.
  Prima facie case requirement for interim injunctions.

3. Relevant Facts of the Case

• The appellant is an education technology (EdTech) start-up operating a website (www.getmyuni.com) that acts as an online platform for students seeking information about universities and colleges in India.

• The website displays details of various universities and colleges offering B.Tech courses, including:
  Rankings based on NIRF parameters.
  Rankings from 'The Week' and 'India Today' magazines.
  Zone-wise lists of colleges.
  Fee structures as available on college websites.

• The respondent universities (Mangalayatan University and Usha Martin University) had earlier engaged in discussions with the appellant for lead generation campaigns. An email dated 23rd February 2020 showed the respondents gave a go-ahead to start the campaign.

• The talks did not materialize into a formal MoU or agreement.

• The respondents filed suits (CS DJ ADJ Nos. 1009/2021 and 1004/2021) seeking:
  Permanent and mandatory injunction restraining the appellant from using the universities' names, information, and details.
  Direction to delete such information from the website.
  Damages of Rs.10,00,000/-.

• The Trial Court allowed the respondents' applications under Order 39 Rules 1 and 2 CPC, restraining the appellant from using the universities' names and details and directing deletion of such information during pendency of the suit.

• The appellant approached the High Court, and vide order dated 22nd May 2023, the operation of the impugned orders was stayed.

• At the time of the High Court hearing, the matters were at the stage of plaintiffs' evidence.

4. Issues Before the High Court
The primary issues for determination were:

1. Whether the Trial Court erred in granting interim injunctions restraining the appellant from displaying publicly available information about the respondent universities on its website?

2. Whether the appellant's use of rankings and other information sourced from public domain (NIRF, magazines) constitutes disparagement of the respondents' reputation?

3. Whether the respondents made out a prima facie case for grant of temporary injunction under Order 39 Rules 1 and 2 CPC?

4. Whether the appellant's website platform is entitled to the protection of exceptions under the Copyright Act and Trade Marks Act for using publicly available data without misrepresentation?

5. Whether the failure of the respondents to challenge the original rankings or exercise their "right to be forgotten" affects their claim for injunction?

5. Ratio Decidendi & Court's Reasoning

The Court allowed the appeals and set aside the impugned orders. The ratio decidendi can be summarized as:

• Publicly Available Information: Information such as NIRF rankings, magazine rankings, and fee structures are publicly available in the open domain. The appellant merely aggregated and displayed this information for the benefit of students. There is no proprietary right that prevents a third party from referencing or compiling such public data.

• No Disparagement Shown: The respondents alleged that the rankings on the appellant's website were disparaging because they did not match Google search results. The Court found this argument unconvincing. The appellant displayed rankings referenced to established ranking agencies (NIRF, 'The Week', 'India Today') and also showed the respondent universities with a score of 4.1 out of 5. There was no evidence that the appellant tinkered with rankings, added editorial comments, or commented on the quality of services.

• No Intellectual Property Appropriation: The respondents did not allege that the appellant appropriated their intellectual property or claimed any association with their marks. The grievance was primarily about hyperlinks directing users to the respondents' websites, which the Court found to be a standard feature of online platforms.

• Prima Facie Case Not Made Out: The Trial Court failed to appreciate that the respondents had not made out a prima facie case for injunction. The emails on record showed the parties were in discussions for collaboration, and the respondents had initially shown interest. The suits appeared to be filed because the MoU discussions did not fructify.

• Failure to Challenge Original Sources: The respondents did not challenge the rankings made by NIRF, 'The Week', or 'India Today' – the original sources of the information. They also did not exercise any "right to be forgotten" by requesting Google to remove their information from search results. This undermined their claim that mere display of such information on the appellant's platform was actionable.

• Right to Use Public Information: An online platform has the right to use publicly available information about educational institutions as long as it is not presented in a disparaging manner. The appellant's website served a public interest function by providing students with comprehensive information to make informed decisions.

6. Legal Principles Established/Reinforced

While the judgment does not establish entirely new law, it clarifies and reinforces several principles in the context of digital platforms and information aggregation:

• Aggregator Platforms and Public Data: Online platforms that aggregate publicly available information (rankings, fees, etc.) from legitimate sources and present it without misrepresentation or disparagement are entitled to protection. Such activity serves a public interest function.

• No Prima Facie Case for Injunction Based on Disparity with Google: The mere fact that rankings or search results on a platform differ from Google's search results does not constitute disparagement. The platform must be shown to have manipulated data or added disparaging editorial content.

• Failure to Challenge Original Source as Relevant Factor: If a claimant does not challenge the original source of information (e.g., NIRF rankings, magazine rankings) but seeks to restrain an aggregator from displaying that same information, it weakens their prima facie case for injunction.

• "Right to be Forgotten" Relevance: The concept of "right to be forgotten" (to have information removed from search results) is acknowledged, and the failure to exercise such right against the original source or primary search engines can be a factor against granting relief against aggregator platforms.

• Commercial Discussions Not Leading to Agreement: The fact that parties engaged in commercial discussions (e.g., for lead generation) which did not culminate in an agreement does not create any legal bar against one party displaying publicly available information about the other.

7. Judicial Analysis & Examination

The Court's analytical approach was structured:

• Contextual Understanding: The Court first understood the nature of the appellant's business – an EdTech platform providing comprehensive information to students.

• Examination of Trial Court's Reasoning: The Court noted that the Trial Court failed to appreciate key aspects: the absence of evidence of manipulation of rankings, the public source of information, and the lack of any disparaging editorial comments.

• Scrutiny of Respondents' Grievance: The Court examined the specific grievance – that rankings did not match Google search results. This was found to be an unconvincing basis for injunction.

• Review of Documentary Evidence: The Court noted the emails on record showing commercial discussions between parties, indicating that the respondents had initially shown interest in collaborating with the appellant.

• Assessment of Prima Facie Case: The Court applied the three-fold test for interim injunctions (prima facie case, balance of convenience, irreparable loss) and found that the respondents failed on the first count.

• Public Interest Consideration: The Court implicitly considered the public interest in access to comprehensive educational information, noting that the impugned orders deprived students of valuable information.

8. Critical Analysis & Final Outcome

• Critical Analysis: The judgment represents a progressive and balanced approach to the rights of information aggregators in the digital age. It correctly recognizes that merely compiling and displaying publicly available information from authoritative sources (NIRF, magazines) without manipulation or disparagement is not an actionable wrong. The Court's observation that the respondents did not challenge the original ranking sources nor exercise any "right to be forgotten" against Google is particularly significant – it prevents claimants from selectively targeting aggregators while leaving primary sources untouched. The judgment also correctly identifies that commercial discussions that do not culminate in an agreement cannot create any estoppel or bar against subsequent display of public information. However, the judgment leaves open the question of what would constitute "disparaging presentation" – future cases will need to define the boundaries. The Court's reference to "right to be forgotten" in the context of educational institutions is interesting, though this right is typically associated with individuals rather than institutions. Nonetheless, the analogy serves to highlight the respondents' failure to seek removal from primary search engines.

• Final Outcome: Both appeals (FAO 126/2023 and FAO 129/2023) were allowed. The impugned orders dated 28th March 2023 passed by the learned ADJ-01, South West District, Dwarka Courts, New Delhi, were set aside. The pending applications were disposed of. The interim stay granted by the High Court on 22nd May 2023 was effectively made absolute. The suits were to proceed to trial, but without the interim injunction against the appellant.