Truth Cannot Be Gagged by Injunction: Madras High Court Refuses Celebrity Chef’s Plea to Restrain Allegedly Defamatory Social Media Posts on Intimate Relationship

“The plaintiff himself admits a relationship – existence of substantial disputed facts disentitles him from pre-trial injunction.”

On January 7, 2026, Justice N. Senthilkumar of the Madras High Court declined to grant interim injunctions in the case of T. Rangaraj v. Ms. Joy Crizildaa & Ors, rejecting an attempt by a celebrity chef and entrepreneur to restrain his alleged partner from making further disclosures on social media regarding their purported marital and intimate relationship. The Court held that the plaintiff had not made out a prima facie case for pre-trial restraint, especially in light of his own admission of a personal relationship and the voluminous material produced by the respondent to substantiate her claims.

The dispute revolved around competing assertions of personality rights, privacy, and defamation on one hand, and freedom of speech and public interest on the other. The Court refused to gag the defendant, citing constitutional and evidentiary thresholds, particularly in defamation matters where the alleged facts are not “palpably false” or devoid of justification.

"Until It Is Clear That an Alleged Libel Is Untrue, It Is Not Clear That Any Right Has Been Infringed": The Bonnard Standard Applies

The plaintiff, T. Rangaraj, a well-known chef and media personality, sought interim relief to prevent Ms. Joy Crizildaa from posting what he called “false, malicious, and defamatory” content about their alleged marital relationship and its fallout. He argued that these disclosures violated his personality rights and severely damaged his commercial reputation. He further claimed that viral re-publication of this content by social media and news channels amounted to commercial exploitation of his identity.

However, the Court invoked the principles laid down in Bonnard v. Perryman (1891), reaffirmed by Indian jurisprudence in Bloomberg Television v. Zee Entertainment (2025), holding that in defamation cases, “prior restraint” should not be granted unless the falsity of the statements is manifest and the defence of justification is bound to fail.

Justice Senthilkumar observed: “The right of free speech is one which it is for the public interest that individuals should possess… unless an alleged libel is untrue, there is no wrong committed… until it is clear that an alleged libel is untrue, it is not clear that any right at all has been infringed.” [Para 25]

Admission of Relationship Weakens Plaintiff’s Case for Injunction

The Court took critical note of the plaintiff's own pleadings, where he acknowledged a personal and close relationship with the defendant, albeit while denying marriage or paternity. Quoting from the plaint, the Court observed: “The plaintiff reposed trust in her and extended friendship in good faith... deceitfully induced the plaintiff into a relationship of confidence.” [Para 22]

Justice Senthilkumar held that such admission, coupled with the existence of photos, WhatsApp chats, and videos showing “intimacy and joy”, created “substantial disputed questions of fact” that must be adjudicated at trial and not gagged at the interim stage. “The plaintiff’s bare denial of cohabitation with the first defendant is nothing but an attempt to escape from the clutches of law,” the Court held. [Para 24]

No Evidence of Commercial Exploitation – No Commercial Dispute Made Out

One of the cornerstones of the plaintiff's argument was that the wide virality of the alleged defamatory content amounted to monetisation of his identity and hence fell under the “commercial dispute” definition under Section 2(1)(c)(xvii) of the Commercial Courts Act, 2015. However, the Court found no material to suggest that the defendant had made commercial gains from the publications.

“Merely furnishing the links and photographs will not be sufficient... the plaintiff has not prima facie established his case,” Justice Senthilkumar ruled. [Para 47]

It was further observed that “none of the second defendants (media platforms or youtubers) had approached either party; the parties themselves were washing their dirty linen in public”. [Para 34]

Voluntary Disclosure of Private Material Disentitles Privacy Claim

In a significant ruling on privacy rights, the Court rejected the plaintiff’s plea that the disclosures violated his right to privacy under Article 21. It noted that both parties had voluntarily exposed their personal relationship in the public domain through interviews, photos, and social media posts.

“Once the parties have put their private moments in public domain, they cannot seek refuge under the right to privacy,” the Court held, relying on the principle laid down in R. Rajagopal v. State of Tamil Nadu (1994) 6 SCC 632. [Paras 27, 34]

The Court also referenced the landmark ruling in Anuradha Bhasin v. Union of India, emphasising that “freedom of speech and expression through internet is constitutionally protected under Article 19(1)(a)” and any restriction must satisfy the test of reasonableness under Article 19(2). [Para 45]

Findings of State Women’s Commission and Pending Criminal Proceedings Cannot Be Ignored

The Court took note of the criminal complaint filed by the defendant and the recommendations of the Tamil Nadu State Commission for Women, which had recorded that the plaintiff admitted to the marriage and paternity. Though later denied by the plaintiff, the Court observed that the said order had not been challenged.

“In such a situation, the Court cannot abridge the evidentiary value of the said materials by claiming them to be fake or concocted,” Justice Senthilkumar held. [Para 43]

Additionally, criminal proceedings had been initiated against the plaintiff under Sections 115(2) and 351(2) of the Bharatiya Nyaya Sanhita, 2023, and the Commission had recommended further prosecution. [Para 35]

"Crocodile Tears Shed by the Plaintiff": Court Criticises Selective Denial and Attempts at Gagging

In a sharply worded observation, the Court remarked: “The crocodile tears shed by the plaintiff disputing the marriage, physical relationship, photographs, videos, Whatsapp chats emanated only when the first defendant aired everything on the social media.” [Para 42]

It further criticised the attempt to use the suit to silence dissent and suppress expression: “The plaintiff is only making an attempt to shut the voice of the individuals or the social media who are airing their views which are against him.” [Para 48]

The Madras High Court’s judgment is a vital reiteration of the balance that must be struck between individual reputation and the fundamental right to freedom of expression. It affirms the Bonnard principle in Indian defamation jurisprudence, recognising that courts must tread with extreme caution before imposing prior restraint, especially where the truth or falsity of the statements is a matter for trial.

With this ruling, the Court has made it unequivocally clear that public figures cannot use the shield of privacy or commercial reputation to suppress inconvenient truths or allegations when substantial issues of fact remain disputed.

Date of Decision: 07.01.2026