CLAT-2027 Blog

Delhi HC’s Landmark Right to Be Forgotten Ruling: Search Engines Must De-Index Sensitive Records

CURRENT AFFAIRS | JUNE 2, 2026

Justice Sachin Datta of the Delhi High Court, in a sweeping 144-page judgment delivered on Friday, 29 May 2026, has held that search engines like Google and legal databases like Indian Kanoon are constitutionally obligated to de-index judgments when name-based searches reveal sensitive matters — acquittals, matrimonial disputes, sexual-offence victims and exonerated accused.

Consolidating 38 petitions, the Court directed legal databases to comply within two weeks and articulated, for the first time in Indian jurisprudence, the doctrine of “informational self-determination” — a concept borrowed from the German Bundesverfassungsgericht.

Constitutional & Legal Framework

  • Article 21: Informational privacy as integral facet of the right to life and personal liberty.
  • K.S. Puttaswamy v. Union of India (2017) — 9-judge Constitution Bench unanimously declared privacy a fundamental right.
  • Article 19(1)(a): Search engines’ free speech rights — subject to reasonable restrictions under 19(2).
  • Article 14: Equality before law — proportionality test in privacy-vs-publication conflicts.
  • IT Act, 2000, Section 79: Intermediary safe-harbour conditioned on due diligence.
  • Digital Personal Data Protection Act, 2023: Statutory framework for data principal rights.
  • Comparative law: GDPR Article 17 (EU’s Right to Erasure).

Judgment Snapshot

Element Detail
Bench Justice Sachin Datta (single judge)
Date 29 May 2026
Length 144 pages
Petitions consolidated 38
Compliance window 2 weeks for legal databases
Doctrine articulated Informational self-determination

Justice Datta observed that, absent de-indexing, “judgments uploaded to the public domain are virtually indelible” — a permanent shadow over an acquitted accused or an estranged spouse decades after the event. The ruling does not mandate removal of the underlying judgment from court records; it requires search-engine results linking a name to those records to be suppressed.

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CLAT 2027 Angle

This is the most exam-relevant privacy ruling since Puttaswamy. Expect comprehension passages testing: (a) the proportionality test (Puttaswamy four-fold formulation — legality, suitability, necessity, balancing); (b) the conflict between Article 19(1)(a) (search-engine speech) and Article 21 (privacy); (c) intermediary liability under IT Act Section 79; and (d) comparative jurisprudence — GDPR Article 17 vs Indian doctrine. The principle established: privacy is the rule, transparency the exception, in personal-identifying contexts.

Mnemonic — “ERASE”

Event — sensitive judgment indexed online | Right under Article 21 (Puttaswamy 2017) | Acquittals, matrimonial, sexual-offence victims | Search engines + databases must de-index | Enforcement window: 2 weeks

The judgment reinforces India’s privacy jurisprudence trajectory — from Govind v. State of MP (1975) through R. Rajagopal v. State of TN (1994) to Puttaswamy — and aligns Indian doctrine with the EU’s “right to erasure”, while preserving press freedom for matters of legitimate public interest.

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