Contempt Has Its Limits: Delhi HC on Google Ads

Contempt Has Its Limits: Delhi HC on Google Ads

New Delhi, July 2026.

For nearly a decade, one Delhi courtroom has been quietly shaping how India expects the world’s biggest search engine to police the trademarks that show up in its adverts. Earlier this month, that long-running dispute reached a decisive moment. The Delhi High Court, ruling on 15 June 2026 in DRS Logistics Private Limited and another versus Google India Private Limited and others, refused to hold Google in contempt over sponsored listings that allegedly kept surfacing under the plaintiffs’ well known packing and moving brand names. The order does more than settle one grievance. It draws a firmer boundary around what search platforms actually owe trademark owners once a court has already spoken, and what counts as genuine defiance versus an honest disagreement about how far an earlier order stretches.

A Dispute Almost a Decade in the Making

The underlying case goes back to a commercial suit filed by DRS Logistics, the company behind the familiar Agarwal Packers and Movers name, along with its associated marks. The suit accused Google and connected defendants of allowing rivals to trigger sponsored advertisements whenever internet users searched for the plaintiffs’ trademarks, effectively siphoning off customers who were looking for one company but landed on a competitor’s page instead.

In October 2021, a single judge of the High Court stepped in with interim directions. Google and the other defendants were told to look into the plaintiffs’ complaints about their trademarks being used as search keywords, examine what effect this was having, and take suitable steps, including removing or blocking advertisements, wherever infringement or passing off was found. Google challenged those directions before a Division Bench, but in August 2023 the bench declined to disturb them.

Matters could have rested there. Instead, the plaintiffs went back to court in 2025, saying that searches conducted that June still threw up sponsored links from third parties whenever their trademarks were typed in. Believing this violated what the 2021 and 2023 orders required, they issued a notice in June 2025 and then filed an application invoking both Order XXXIX Rule 2A of the Civil Procedure Code and Section 12 of the Contempt of Courts Act, asking the court to treat Google’s continued conduct as wilful disobedience.

Two Very Different Readings of the Same Order

At the heart of the fight sat a single question of interpretation. The plaintiffs read the earlier orders broadly. They pointed to an assurance Google itself had given the court years before, back in January 2020, that under its own advertising rules, no third party would be allowed to use another company’s trademark inside advertisement text, advertisement titles, or the visible URL of an advert. If that promise had been made and accepted by the court, the plaintiffs argued, then any resurfacing of their marks in that context, however it happened, amounted to defying a standing judicial direction.

Google and its co-conspirators responded with a more cramped interpretation. Their position was that the 2021 and 2023 orders were really about one specific practice: the use of trademarks as backend search keywords that trigger which adverts appear, not about actively hunting down and blocking every advertisement that might mention a rival’s brand in its wording. Investigating complaints as they came in, they argued, was very different from being placed under a standing duty to monitor the entire advertising ecosystem in real time.

The High Court had to decide which of these readings actually matched what the earlier bench had ordered, and whether the gap between them was wide enough to count as wilful disobedience at all.

How the Court Reasoned Through It

Justice Tejas Karia, hearing the matter, traced the origin of the 2021 directions back to that January 2020 hearing where Google had explained its advertising policy to the court. Because the plaintiffs had accepted that explanation at the time and chosen to press their injunction plea specifically around keyword usage, the resulting directions were shaped around that narrower controversy. In other words, the scope of what the court eventually ordered was tied to what the plaintiffs themselves had chosen to argue for at that stage, not the wider protections they were now trying to read into it after the fact.

This reasoning connected to a well-established line of Supreme Court authority on contempt jurisdiction. The court leaned on the principle, drawn from cases including Sudhir Vasudeva versus M. George Ravishekaran, that contempt can only be built on directions that are clear, explicit, and leave no real room for debate. Additional precedents reinforced the same idea: where a court order is capable of more than one reasonable reading, and the alleged contemnor’s understanding of it was not unreasonable, contempt proceedings are simply not the right tool, regardless of how frustrated the other side might feel.

Applying that framework, the bench concluded that the 2021 and 2023 orders never actually required Google to proactively police every advertisement for trademark mentions in text, titles, or URLs. What they required was a functioning complaint mechanism, investigation of what was reported, and corrective action where infringement was genuinely found. The court did note, however, that Google remained bound by its own recorded commitment that such usage was against its advertising policy and would be addressed once flagged, so the obligation to act on complaints has not disappeared; it simply is not the same as a duty of constant surveillance.

The Outcome and What the Plaintiffs Still Have

The contempt application was dismissed. The court found no evidence of wilful disobedience, particularly since the specific URLs the plaintiffs had complained about had already been taken down once notice was given, and the matter came back before the court. That fact mattered, since it showed the complaint-driven system was actually functioning rather than being ignored.

The plaintiffs were not left empty-handed, though. The Court specifically reserved its right to report future advertisements that may infringe upon their trademark rights in text, titles, and/or URLs, and ordered that they take up all such reported complaints on a priority basis when they arose. So the case closes not with a blanket win for either side, but with a clearer rulebook for how the relationship between trademark owners and the platform is supposed to work going forward.

Why This Matters Well Beyond One Logistics Company

Keyword advertising disputes are not new, either in India or globally, but this ruling lands at a useful moment because it separates two questions that often get blurred together in public debate: whether a platform’s advertising policy creates enforceable obligations, and whether contempt of court is the right vehicle to enforce those obligations when they are allegedly breached. The judgment answers the second question quite firmly. Contempt is reserved for clear, unambiguous defiance, not for stretching an old order to cover new grievances, however legitimate those grievances might feel to the party raising them.

For trademark owners running a brand with a real digital footprint, the practical lesson is that a complaint-driven enforcement relationship with a platform like Google is workable, but it depends on actually using that channel every time new infringing material appears, rather than assuming a year-old order will automatically keep catching new violations on its own. For platforms and intermediaries, the judgment offers some reassurance that clearly worded policies, consistently applied when complaints come in, can satisfy a court’s expectations without requiring an impossible standard of constant, proactive monitoring across millions of advertisements.

It also fits into a broader pattern playing out across Indian courts this year, where judges are being asked again and again to work out where a digital platform’s responsibility actually starts and ends, whether the subject is trademarks, deepfakes, or AI-generated content. Each of these rulings adds another data point to what is still a developing, and at times inconsistent, body of law on intermediary accountability in India. DRS Logistics versus Google India is unlikely to be the last word on keyword advertising, but for now it stands as a clear, carefully reasoned statement on the limits of contempt jurisdiction in the online trademark space, and a useful reminder that even a decade-long fight can end not in a dramatic verdict, but in a sensible clarification of what was actually promised in the first place.

Case details: DRS Logistics (P) Ltd. and Another v. Google India Pvt. Ltd. and Ors., CS(COMM) 1/2017, Neutral Citation 2026:DHC:5102, decided 15 June 2026 by Justice Tejas Karia, Delhi High Court.

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