Justice Anup Jairam Bhambhani of the Delhi High Court has declined to decide, at the level of a single judge, whether the mere accessibility of online content within Delhi is enough to give Delhi courts territorial jurisdiction in an intellectual property or disparagement suit. By order dated 25 August 2026, he referred the question to a larger bench in Hindustan Unilever Limited v. Kwick Living (I) Private Limited.
Hindustan Unilever sued for a permanent injunction against an advertisement campaign titled "War on What's Hidden", which it said disparaged its Vim and Surf Excel products through unsubstantiated claims. Both companies are headquartered in Mumbai and the disputed hoarding was in Mumbai. HUL argued that Delhi courts had jurisdiction because it has a corporate office in Delhi and the campaign was also accessible in Delhi on YouTube, Instagram and Kwick Living's website.
Noting conflicting Supreme Court and Delhi High Court precedent on whether online accessibility within a forum, without more, can found territorial jurisdiction, the Court referred the question to a larger bench instead of resolving it itself.