Judgment analysis, MP High Court at Jabalpur
In Anjali Singh v. Union of India, a single judge of the Madhya Pradesh High Court at Jabalpur dealt with a petition about allegedly edited video clips, online threats and alleged inaction on complaints. The Court did not decide whether the videos were genuine or defamatory. It sent the complaints back to the authorities with five directions. This note explains what the order settles and what it leaves open for anyone weighing a legal remedy for edited videos.
Legal remedy for edited videos: why this order matters
The petitioner in Anjali Singh v. Union of India asked the Madhya Pradesh High Court for removal of online content, identification of the people behind it, protection for her family and an investigation. Those are the same things many people have in mind when they look for a legal remedy for edited videos.
The order was passed by Justice Himanshu Joshi on 20 August 2026 in Writ Petition No. 33764 of 2026 (neutral citation 2026:MPHC-JBP:65926). It does not rule on whether the videos were edited, defamatory or inflammatory. It sets out a division of labour: the writ court leaves disputed facts and content-specific questions to the authorities, while insisting that preservation of electronic evidence and personal safety are not ignored.
The holding in one sentence
The High Court declined to decide whether the videos were genuine, defamatory or inflammatory, or to order a blanket takedown, and instead directed the police, cyber authorities and the Commissioner of Police to consider the complaints, preserve electronic evidence, examine the specific content under the IT Act and Rules, and assess the threat, all in accordance with law.
The dispute: what the petitioner alleged
Everything in this section is the petitioner’s account, as recorded in the order. The Court made no finding on it.
She was involved in civil and administrative disputes about the management of a residential enclave in Bhopal. She said parking blocks outside her residence were removed on the night of 23 July 2026 and were being restored on 24 July 2026 when an altercation took place, and that the incident was recorded on CCTV and in an unedited video. She alleged that portions were then selectively edited and circulated on social media with captions that gave the incident a communal colour and falsely attributed religious remarks to her.
She said threatening calls and messages followed. She complained to the police, the State Cyber Police and the National Cyber Crime Reporting Portal from 29 July 2026 onwards, sent a representation on 6 August 2026 invoking the IT Rules, 2021 to seek removal of the content and preservation of electronic evidence, and gave her statement to the police on 10 August 2026. Despite more than fifteen complaints and representations, she said, the material kept circulating and no effective action was taken.
She asked for directions to the State authorities and the social-media intermediaries, preservation of electronic evidence, identification of those responsible, protection for herself and her family, registration and investigation of the alleged cyber offence, and action under the Information Technology Act, 2000 and the IT Rules.
The law and the arguments
The petition and the arguments rested on the following framework:
- Article 226 of the Constitution: the source of the High Court’s writ power.
- Article 21 and privacy: the petitioner argued that the State has a positive obligation to protect her life and liberty, and relied on K.S. Puttaswamy (Retd.) v. Union of India, (2017) 10 SCC 1, for the proposition that privacy is a constitutionally protected right.
- Information Technology Act, 2000 and the IT Rules, 2021: the statutory mechanism for complaints about online content and for intermediaries’ grievance redressal.
- Bharatiya Sakshya Adhiniyam, 2023, Section 63: the certificate filed with the pen-drive of original footage (Annexure IA/1).
The petitioner argued that continued circulation threatened her reputation, dignity, privacy and safety, that the authorities had not acted under the IT Rules despite complaints identifying specific URLs, and that the intermediaries had not met their grievance-redressal obligations. She also cited the Kerala High Court decision in Anto Augustine & Others v. Union of India & Others, W.P.(C) No. 9839/2024, on the statutory mechanism under the Rules.
The respondents said the case raised disputed questions of fact unsuitable for writ jurisdiction, that her complaints had already gone to the competent police and cyber authorities, that her statement was recorded and that action was being taken in accordance with law. They added that no blanket direction to remove content or disclose user details could issue without following the procedure under the IT Act and the Rules.
The Court did not interpret any specific section of the Act or the Rules, and it did not discuss the two decisions the petitioner cited.
How the Court reasoned
Facts are for the investigators, not the writ court
The Court held that the grievance raises factual questions: whether the videos are authentic and complete, who edited or circulated them, the context in which the statements were made, and whether the material attracts any penal or statutory provision. Those questions, it said, are appropriately examined by the competent investigating agency on the original electronic material and other evidence.
A comparable limit on writ jurisdiction, in a very different setting, is discussed in this analysis of the narrow lane of writ jurisdiction in a government lease dispute, where the Court examined the decision-making process and left money claims to arbitration.
No blanket takedown order
The Court said it would not be justified, at this stage, in recording a finding that the videos are defamatory, communally inflammatory or “synthetically generated information”, because such findings need examination of the original material and the statutory framework. For the same reason, a blanket direction to the private intermediary respondents to remove all such content, without identifying and examining the specific offending material, cannot ordinarily be issued in writ jurisdiction.
The door was not shut. The petitioner may place the specific URLs, account details, screenshots and copies of the original footage before the competent authority and the intermediaries, and the authority must consider the grievance under the IT Act and the Rules. Nothing in the order prevents it from issuing a direction or communication to an intermediary if the statutory requirements are satisfied.
Evidence and safety cannot wait
The grievances about preserving electronic evidence and about personal safety, the Court held, could not be ignored. Because the complaints showed that the police and cyber authorities already knew of the matter, they were required to consider them in accordance with law, particularly on preservation of evidence and investigation of any cognizable offence. The Commissioner of Police, Bhopal, was to examine the petitioner’s representation dated 2 August 2026 and, after a threat assessment, take such preventive measures as may be warranted.
No particular agency on apprehension alone
On immediate registration of an FIR and transfer of the investigation, the Court left the complaints to the competent police authority. It added that a petitioner cannot seek a direction for a particular agency to investigate merely on apprehension, without material showing that the existing investigation is unfair or incapable of being conducted impartially.
What the Court ordered on each prayer
The petition was disposed of with five directions. The table maps each relief the petitioner sought to what the Court did, which shows the route to a legal remedy for edited videos that this order marks out.
| Relief sought | What the Court did |
|---|---|
| A finding that the videos are defamatory, communally inflammatory or synthetic | Declined to record any finding at this stage |
| Blanket removal of content by intermediaries | Not ordinarily available in writ jurisdiction without identifying the specific material; petitioner may place URLs, accounts, screenshots and original footage before the authority and intermediaries |
| Preservation of electronic evidence | Police or cyber authority to act, including preservation, and to consider the original CCTV footage and unedited video |
| Registration of an FIR and transfer of investigation | Police to consider the complaints in accordance with law and proceed if a cognizable offence is disclosed; no particular agency on apprehension alone |
| Action under the IT Act and the IT Rules | Competent authority to examine the grievance on the specific content and act where statutory requirements are satisfied |
| Police protection | Commissioner of Police, Bhopal, to consider the request and take preventive measures on the basis of a threat assessment |
What the Court left open
- The merits. The Court expressed no opinion on whether the videos are genuine or lawful, on the rival allegations arising from the incident, or on the culpability of any person.
- Who the competent authority is. The directions refer to the competent police, cyber and IT Act authorities without naming an officer, and the order sets no deadline.
- The intermediaries’ position. The order refers to private intermediary respondents, but the appearances it records are for the Union of India and the State only. It records no stand by any intermediary and issues no direction to one.
- The exceptions to the takedown rule. A blanket removal direction ordinarily cannot be issued, but the order does not say when an exception might arise.
- The threshold for changing the agency. The Court mentioned material showing that the existing investigation is unfair or incapable of impartial conduct, without elaborating.
Legal remedy for edited videos: records to assemble
The order is not a checklist and promises nothing about outcomes. But it names what the Court expected to be placed before the authorities, and it records what the petitioner had already gathered.
What the order says to place before the authorities
- The specific URLs of the content
- Account details
- Screenshots
- Copies of the original or unedited footage
What the record in this case contained
- Dated complaints to the police, the State Cyber Police and the National Cyber Crime Reporting Portal
- A dated representation invoking the IT Rules, 2021, seeking removal of the content and preservation of electronic evidence
- A dated representation (Annexure P/5) that the Commissioner of Police was directed to examine on the prayer for protection
- CCTV footage and the unedited video in a pen-drive with a certificate under Section 63 of the Bharatiya Sakshya Adhiniyam, 2023 (Annexure IA/1)
Conclusion
The order settles a narrow but useful point. In this order the Court did not use Article 226 to decide authenticity, context or culpability, and said that a blanket takedown direction to intermediaries ordinarily cannot be issued. It treated preservation of electronic evidence and personal safety as matters that cannot be ignored, and directed the police, cyber authorities and the Commissioner of Police to consider the complaints and act in accordance with law. It leaves open the identity of the competent authority, any timeline, the intermediaries’ position, the exceptions to the takedown rule and what would justify a change of agency. Because the Court stayed away from the merits, the order is best read for its approach to the prayers, not as a ruling on the videos or the IT Rules.
For litigants, the practical message is that, on this order, a legal remedy for edited videos in the High Court rests on specific content, a dated complaint trail and original material, with the outcome left to the authorities and the law. For the establishment, the message is equally plain: complaints that have reached the police and cyber authorities carry a duty to be considered, evidence is to be preserved and a threat assessment is to be made, without the Court pre-judging the dispute.
Judgment at a glance
Case Summary
- Case title
- Anjali Singh v. Union of India and Others
- Court
- High Court of Madhya Pradesh at Jabalpur
- Bench
- Justice Himanshu Joshi (single judge)
- Date of order
- 20 August 2026
- Neutral citation
- 2026:MPHC-JBP:65926
- Case number
- Writ Petition No. 33764 of 2026
- Jurisdiction invoked
- Article 226 of the Constitution of India
- Statutes referred to
- Information Technology Act, 2000; IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; Bharatiya Sakshya Adhiniyam, 2023 (Section 63)
- Outcome
- Petition disposed of with five directions to the authorities, without any opinion on the merits
Key Takeaways
What Anjali Singh v. Union of India (WP 33764/2026) settles, in four points.
- 01
Disputed facts stay with the investigators
Authenticity, completeness, who edited or circulated the clips and their context were treated as questions for the competent investigating agency.
- 02
No blanket takedown, but specific content is the way in
A direction to remove all such content cannot ordinarily be issued in writ jurisdiction. The petitioner may place URLs, account details, screenshots and original footage before the authority and intermediaries.
- 03
Evidence and safety are not ignored
Authorities must consider the complaints, including preservation of electronic evidence, and the Commissioner of Police must make a threat assessment.
- 04
No view on the merits
The Court did not opine on the genuineness or legality of the videos or the culpability of any person.
Frequently Asked Questions
Edited videos, takedown requests and writ petitions: what the order says.
A single judge of the Madhya Pradesh High Court at Jabalpur, Justice Himanshu Joshi, decided it on 20 August 2026 in a petition under Article 226 of the Constitution. The order does not say that a writ petition is the right or only route for every such complaint. It records the respondents' objection that disputed facts cannot be decided in writ jurisdiction, and it leaves factual questions to the competent investigating agency.
No. The Court said it would not record a finding at this stage that the videos are defamatory or communally inflammatory, because that needs examination of the original material and the statutory framework. It expressed no opinion on the genuineness or legality of the videos, the rival allegations, or the culpability of any person.
Ordinarily not as a blanket direction, going by this order. The Court said a direction to remove all such content, without identifying and examining the specific offending material, cannot ordinarily be issued in writ jurisdiction. It allowed the petitioner to place specific URLs, account details, screenshots and original footage before the competent authority and the intermediaries.
It gave five directions. The police or cyber authority must consider the complaints, including preservation of electronic evidence. The competent authority must examine the grievance on the specific online content under the IT Act and Rules. The Commissioner of Police, Bhopal, must consider protection on the basis of a threat assessment. The investigating authority must consider the original footage, and proceedings must follow if a cognizable offence is disclosed.
No. The order does not deal with limitation or delay and sets no deadline for the authorities. It records the petitioner's case that she complained from 29 July 2026 onwards and that, despite more than fifteen complaints and representations, no effective action was taken, but it makes no finding on the timing of any step.
The Court said the petitioner could place the specific URLs, account details, screenshots and copies of the original or unedited footage before the competent authority and the intermediaries. The record in the case also included dated complaints and representations, and the original video and CCTV footage in a pen-drive with a certificate under Section 63 of the Bharatiya Sakshya Adhiniyam, 2023.
A person whose complaints about online content or threats have not been acted on may consider taking advice from an advocate practising at the Madhya Pradesh High Court on whether a petition under Article 226 suits their facts. This order shows the Court looking at complaints already made, specific content and alleged threats, and then directing authorities to act in accordance with law. Suitability depends on the record in each case.
Important Precedents Discussed or Relied Upon
Two decisions were cited by the petitioner. The Court did not cite or discuss any decision in its own reasoning.
Supreme Court
K.S. Puttaswamy (Retd.) v. Union of India
(2017) 10 SCC 1
Cited by the petitioner for the proposition that privacy is a constitutionally protected right. The order does not discuss it further.
High Court
Anto Augustine and Others v. Union of India and Others
W.P.(C) No. 9839/2024, Kerala High Court
Cited by the petitioner in support of her submissions on the statutory mechanism under the IT Rules. The order does not discuss it further.
Provisions
Article 226, Constitution of India
Writ jurisdiction
The jurisdiction invoked for directions to State authorities and intermediaries. The Court treated disputed facts and blanket takedown as unsuitable for writ jurisdiction.
Provisions
Information Technology Act, 2000 and IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
Statute and rules
The framework under which the competent authority is to examine the grievance on specific content. No individual provision is analysed.
The provisions are listed for reference alongside the two decisions.

Advocate Siddharth Shukla
Principal Seat of the Madhya Pradesh High Court at Jabalpur
- Practice areas: service and constitutional law, civil appeals, labour law, arbitration, corporate law and taxation
- Appears before: the Madhya Pradesh High Court, the CAT Jabalpur Bench and the CGIT
- Office: Second Floor, CARAVS Building, 15, South Civil Lines, Jabalpur, MP 482001
- Bar enrolment: MP/1518/2012
