Delhi High Court - Orders
Bajaj Finance Limited vs Manish Singh @ Settlement Guru & Ors on 22 January, 2026
Author: Tushar Rao Gedela
Bench: Tushar Rao Gedela
$~52
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CS(COMM) 63/2026
BAJAJ FINANCE LIMITED .....Plaintiff
Through: Mr. Karan Luthra, Mr. Ankit Banati,
Ms. Aarushi Tiku, Mr. Piyush Thanvi,
Advocates.
versus
MANISH SINGH @ SETTLEMENT GURU & ORS.....Defendants
Through: Mr. Rohan Jaitley, CGSC with Mr.
Akshay Sharma, G.P, Mr. Dev Pratap
Shahi, Mr. Varun Pratap Singh, Ms.
Yogya Bhatia, Advocates for UOI.
Mr. Ankit Parhar and Mr. Abhishek
Kumar, Advocates for D-3 (X Corp.)
Mr. Neel Mason, Ms. Ekta Sharma,
Mr. Udit Tewari, Ms. Surabhi Katare,
Advocates for D-4/Google LLC.
CORAM:
HON'BLE MR. JUSTICE TUSHAR RAO GEDELA
ORDER
% 22.01.2026 I.A. 1852/20262026 (Additional Documents)
1. The present application has been filed on behalf of the plaintiffs under Order XI Rule 1(4) of the Code of Civil Procedure, 1908 ("CPC") as applicable to commercial suits under the Commercial Courts Act, 2015 ("CC Act") seeking leave to place on record additional documents.
2. As prayed, the plaintiff is permitted to file additional documents in accordance with the provisions of the CC Act and the Delhi High Court (Original Side) Rules, 2018 within thirty (30) days.
3. Accordingly, the application stands disposed of.
CS (COMM) 63/2026 Page 1 of 13This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 I.A. 1853/2026 (Pre-Institution Mediation)
4. This is an application filed by the plaintiff seeking exemption from Pre- Institution Mediation under Section 12A of the CC Act.
5. As the present matter contemplates urgent interim relief, in light of the judgment of the Hon'ble Supreme Court in Yamini Manohar v. T.K.D. Keerthi, (2024) 5 SCC 815, exemption from the requirement of Pre- Institution Mediation is granted.
6. The application stands disposed of.
I.A. 1854/2026 2026 (Exemption from filing legible/certified copies)
7. This is an application filed on behalf of the plaintiff under Section 151 of the CPC seeking exemption from filing original/certified, typed, translated from vernacular and illegible copies of the documents.
8. For the reasons stated therein, exemption is allowed, subject to all just exceptions.
9. The clear, original, certified, typed, translated and legible copies of the documents upon which they seek to place reliance, be filed within four weeks.
10. The application stands disposed of.
I.A. 1855/2026 (seeking leave to file certain documents on a CD/pendrive)
11. This application has been filed by plaintiff seeking permission to place on record CD/pendrive containing video clips of defendants' infringing activities.
12. For the reasons stated therein, the same is allowed. The CD/pendrive be filed within two weeks and be taken on record.
13. Accordingly, the application stands disposed of. I.A. 1851/2026 (Stay)
14. This is an application filed by the plaintiff under Order XXXIX Rule 1 & 2, CPC seeking ad interim injunction against the defendants.
CS (COMM) 63/2026 Page 2 of 13This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07
15. Plaintiff is a public limited company incorporated under the erstwhile Companies Act, 1956 and a company under Section 2(20) of the Companies Act, 2013, having its office at 11th Floor, Aggarwal Metro Heights, Netaji Subhash Place, Pitampura, New Delhi. The plaintiff is a Non-Banking Financial Company (NBFC-D) registered with the Reserve Bank of India (RBI). Plaintiff is engaged in the business of lending and acceptance of public deposits apart from a diversified lending portfolio across retail, SMEs and commercial customers across India. Such services are claimed to have commenced from the year 2007. Plaintiff claims to have a current loan book of Rs.36.37 million and is rated as "AAA" by CRISIL, ICRA and CARE.
16. Plaintiff claims to be a part of the Bajaj Group which has a presence in automotive, finance, home appliance sectors etc. The plaintiff claims that "Bajaj" has become a well-known household name and enjoys excellent goodwill and reputation in the market. The plaintiff's networth is claimed to be more than Rs.96,700 Crores as on 31.03.2025 and a balance sheet size of Rs.3,67,869.56 Crores as on 31.03.2025.
17. Plaintiff claims to have been accorded many awards which are enlisted in para 15 of the plaint. Plaintiff claims to have lakhs of public shareholders including various banks and mutual funds and employees more than 64,092 direct employees. The details of personal and retail loans granted by the plaintiff in the last three financial years are provided in para 17 of the plaint with the FY 2023-24 clocking Rs.38.20 million. Para 18 of the plaint gives the details of plaintiff's trademark registrations of the word "Bajaj Finance"
in Class-36 i.e. Financial and Real Estate Affairs. The same are enumerated hereunder:
S.NO. DATE OF TRADEMARK NO. TRADEMARK DATE OF
APPLICATION REGISTRATION
CS (COMM) 63/2026 Page 3 of 13
This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07
1. 17.03.2008 1665234 Bajaj Finance 15.12.2010
2. 17.03.2008 1665235 Bajaj Finance 15.12.2010
3. 19.05.2023 594416 05.06.2024
4. 19.05.2023 5944517 04.06.2024
5. 19.05.2023 5944518 10.05.2024
6. 19.05.2023 5944519 25.05.2024
7. 30.05.2023 5959017 05.05.2024
8. 30.05.2023 5959019 07.05.2024
9. 19.05.2023 5944520 06.05.2024
18. The details of the expenditure incurred by the plaintiff in marketing and promoting its services in the last five financial years are contained in para 19 of the plaint and for the FY 2024-25, the plaintiff claims to have expended an amount of Rs.461.24 Crores. The loans which are expended to customers/borrowers are returned through payments of regular equated monthly installments (EMIs). In order to effect timely recovery of loans, every banking and financial institution, including the plaintiff, is permitted to engage recovery agents for assistance. Plaintiff states that RBI regulates the entire banking system in the country and has issued a Circular dated 24.04.2008 which governs the engagement of Recovery Agents and the good CS (COMM) 63/2026 Page 4 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 practices to be followed.
19. Plaintiff claims that the defendant no.1 is operating and running a platform by the name "SettlementGuru" without any legal basis and is being run only on social media platforms owned by defendant nos.2 to 4. The list of such platforms and the URLs are mentioned in para 26. The defendant no.1 is also alleged to be running a website, "www.settlementguru.in" and is stated to have claimed as under:
"Settlementguru holds expertise in ensuring that you settle you Debt for less than your outstanding. We also make sure that you start rebuilding your creditworthiness soon after Debt settlement. ls Settlementguru the key that unlock your financial freedom for you to start fresh".
Similarly, in YouTube page, the platform is described as under:
20. Plaintiff submits that on the aforesaid social media platform, the defendant no.1 is unlawfully and tortiously interfering in the lawful business of the plaintiff by encouraging and inducing the customers and borrowers to deliberately and willfully breach their contracts with the plaintiff by defaulting on the repayments of their loans/EMIs on the assurance that the defendant no.1 would ensure a settlement with the plaintiff for an amount significantly lesser than the actual outstanding loan of the customers/borrowers. According to the plaintiff, defendant no.1 by such illegal and unlawful actions is inducing the customers/borrowers of the CS (COMM) 63/2026 Page 5 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 plaintiff to breach the conditions of the lawfully executed contracts. The plaintiff alleges that the defendant no.1 puts false and misleading information on the platform in the form of call recordings between a customer or a borrower and a purported loan recovery agent, alleged to be that of the plaintiff. The defendant no.1 is also alleged to display settlement letters alleged to be executed between the plaintiff and its customers using the trademark of the plaintiff. That apart, the defendant no.1 is stated to be falsely representing that the plaintiff is harassing customers/borrowers through their loan recovery agents. Plaintiff claims that such call recordings are stage managed and uploaded on the social media platform managed by defendant no.1. One such video uploaded on Instagram with the URL https://www.instagram.com/reel/DMu5g0pCRgd/ is mentioned in para 34 of the plaint, alongwith the image, which is extracted hereunder:
21. In Para 42 of the plaint, the plaintiff has pasted the image of the Instagram page displaying the registered trademark of the plaintiff purportedly being used on a letter-head of the plaintiff in respect of a purported letter of settlement. Plaintiff states that by such methods, defendant CS (COMM) 63/2026 Page 6 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 no.1 is not only misleading the general public by such actions but is also earning monies at the expense of inducing loan defaults. These actions are being undertaken in order to earn revenues by the defendant no.1.
22. The list of impugned URLs/Weblinks as enumerated in para 48 of the plaint, is extracted hereunder:
(i) https://www.instagram.com/reel/DMu5g0pCRgd/
(ii) https://www.youtube.com/watch?v=muEhLFDTYl8
(iii) https://www.youtube.com/watch?v=ZWAAn9m5f_A
(iv) https://www.instagram.com/reel/DLytO34vqMw/
(v) https://www.youtube.com/watch?v=92AWOWmEJVI
(vi) https://www.instagram.com/reel/DLwd1qfPzGv/
(vii) https://www.youtube.com/watch?v=Dko6lyQD140
(viii) https://www.youtube.com/watch?v=lWGFgZoAEgQ
(ix) https://www.youtube.com/watch?v=JOzERABmz9c
(x) https://www.youtube.com/watch?v=EzCGTuS8rH4
(xi) https://www.instagram.com/reel/C-CAZoWPNB4/
(xii) https://www.youtube.com/watch?v=jAaaMN1teco
(xiii) https://www.youtube.com/watch?v=jAaaMN1teco
(xiv) https://twitter.com/Settlementguru1/status/1817757651318526383
(xv) https://twitter.com/Settlementguru1/status/1817387705841701213 (xvi) https://www.youtube.com/watch?v=1tbU7QTur9Y (xvii) https://twitter.com/Settlementguru1/status/1803994189837013105 (xviii) https://www.youtube.com/watch?v=WghQ9M_4y_A (xix) https://www.youtube.com/watch?v=suMfMrNAKok (xx) https://www.instagram.com/reel/C8KBqTgvDCP/ (xxi) https://twitter.com/Settlementguru1/status/1801236702817886628 (xxii) https://www.instagram.com/reel/C8Jr6kIvHEk/ (xxiii) https://twitter.com/Settlementguru1/status/1801189152182149357 (xxiv) https://twitter.com/Settlementguru1/status/1801176014292492732 (xxv) https://www.youtube.com/watch?v=CYV9ydnBo7o (xxvi) https://twitter.com/Settlementguru1/status/1801104843991667028 CS (COMM) 63/2026 Page 7 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 (xxvii) https://www.youtube.com/watch?v=-7TxWTeXI80 (xxviii) https://www.youtube.com/watch?v=dCIOIvakJXY. (xxix) https://twitter.com/Settlementguru1/status/1791317753284153508 (xxx) https://www.instagram.com/reel/C6V01ilrLfE/ (xxxi) https://twitter.com/Settlementguru1/status/1784879119240466743 (xxxii) https://twitter.com/Settlementguru1/status/1732618637184577717 (xxxiii)https://twitter.com/Settlementguru1/status/1725002795991069112 (xxxiv) https://www.instagram.com/reel/CzsWEvnrBLj/ (xxxv) https://twitter.com/Settlementguru1/status/1725001477209657711 (xxxvi) https://twitter.com/Settlementguru1/status/1720000157423751582 (xxxvii) https://twitter.com/Settlementguru1/status/1713861184934531545 (xxxviii) https://www.instagram.com/reel/CydK0siLLru/ (xxxix) https://twitter.com/Settlementguru1/status/1707383808658739638 (xl) https://www.instagram.com/reel/CxvJmkNvvpr/ (xli) https://twitter.com/Settlementguru1/status/1707380700591353887 (xlii) https://twitter.com/Settlementguru1/status/1690280442770161664 (xliii) https://twitter.com/Settlementguru1/status/1689865339457421312 (xliv) https://twitter.com/Settlementguru1/status/1688083284528672769 (xlv) https://twitter.com/Settlementguru1/status/1655483165094412292 (xlvi) https://twitter.com/Settlementguru1/status/1655432421662396421 (xlvii) https://twitter.com/Settlementguru1/status/1643112934380568576 (xlviii) https://twitter.com/Settlementguru1/status/1641299029874348033 (xlix) https://twitter.com/Settlementguru1/status/1640988790188806144
(l) https://www.instagram.com/settlementguru/reel/DNsDdJQ5EvD/ (li) https://www.instagram.com/settlementguru/reel/DNj3AQkpSP/ (lii) https://www.instagram.com/settlementguru/reel/DOqAfujkvM3/ (liii) https://youtu.be/o2VgB4jS6fs (liv) https://www.instagram.com/settlementguru/reel/DOqAfujkvM3/ (lv) https://www.instagram.com/settlementguru/reel/DPV2J4NDQAQ/ (lvi) https://www.instagram.com/settlementguru/reel/DPdxdIjtYd/ (lvii) https://www.instagram.com/settlementguru/reel/DPlBX03Emh3/ (lviii) https://www.instagram.com/settlementguru/reel/DPlvJq_Av64/ CS (COMM) 63/2026 Page 8 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 (lix) https://youtu.be/gPnktZI42pw (lx) https://www.instagram.com/settlementguru/reel/DPqb6BnkqvC/ (lxi) https://www.instagram.com/settlementguru/reel/DQWqWKNkhvm/ (lxii) https://www.youtube.com/shorts/OrvtRSl0cSI?feature=share (lxiii) https://www.instagram.com/settlementguru/reel/DQ8TT5qEj2o/ (lxiv) https://www.youtube.com/shorts/zIRHBMS_wWY?feature=share (lxv) https://www.youtube.com/watch?v=mMZITJ1JER4&t=5s (lxvi) https://www.instagram.com/reel/DSXUK-
5kzq2/?igsh=cmdkeWhmb2x6YmJi (lxvii) https://www.instagram.com/reel/DScCwEOk5oq/?igsh=MTcyd3Q2MWg2a jN5bA== (lxviii) https://www.instagram.com/reel/DSclVRsk5XH/?igsh=MWNheTJuZGpoN 3BpOA== (lxix) https://www.youtube.com/watch?v=A6n15ioe45A (lxx) https://www.instagram.com/reel/DSe1D4fE-
7i/?igsh=NXBzaXVkNmd1NmF4 (lxxi) https://www.instagram.com/reel/DSwjjoek54a/?igsh=cWs3OTRodjZkNXhz (lxxii) https://www.youtube.com/shorts/jspC9h83ckI
23. Plaintiff states that the contents of the information being spread around are false, misleading, stage managed and per se defamatory apart from infringement of the plaintiff's registered trademarks. Plaintiff claims to have filed certain criminal proceedings before the appropriate Criminal Courts in order to protect itself. Plaintiff claims that all these actions came to its knowledge initially in the month of August, 2023 and later in October- November, 2025 when certain customers orally informed that they would not be fulfilling their obligations under the loan agreements, after contacting the defendant no.1 who assured them of significant discounts on their one-time settlement.
24. Predicated on the above, the plaintiff seeks an ex-parte ad-interim CS (COMM) 63/2026 Page 9 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 injunction against defendant no.1 and other defendants as well.
25. Having heard learned counsel for the parties and perusing the relevant paragraphs of the plaint and the documents placed on record, it appears that the social media platforms and other URLs belonging to the defendant no.1 are being misused by the defendant no.1 to infringe the registered trademarks of the plaintiff. The plaintiff is a NBFC having been accorded many awards. The networth of the plaintiff as also the promotional and advertising expenditure incurred over the last many years coupled with the balance sheet size, market cap and huge customer base indicate its exponential growth over the years. The plaintiff has also demonstrated that its trademarks have been continuously and regularly used by it.
26. The use of the plaintiff's trademarks by the defendant no.1 in the form of purported settlement deeds displayed unauthorizedly on the social media platforms and URLs belonging to defendant no.1, prima facie, appears to be dishonest. The plaintiff has made out a case of ex-parte ad-interim injunction. Since the trademarks of the plaintiff are registered, the balance of convenience is tilted in favour of the plaintiff and in case, ex-parte ad-interim injunction is not granted, the reputation and goodwill of the petitioner may be injured.
27. Accordingly, the following directions are passed:
a) The defendant no.1 or anyone acting on its behalf is restrained from directly or indirectly, unlawfully and tortiously interfering in the business of the plaintiff by inducing, inciting, and misleading the customers/borrowers of the plaintiff to deliberately breach the terms of their executed contracts i.e. Loan Agreements with the plaintiff, by making any references to the plaintiff, its registered trademarks and/or its business, in the content being published, circulated, disseminated CS (COMM) 63/2026 Page 10 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 and uploaded by defendant no.1 on social media platforms owned by defendant nos.2 to 4.
b) The defendant no.1 or anyone acting on its behalf is restrained from maligning the goodwill and reputation of the plaintiff by publishing in any manner per se defamatory and malicious statements on the social media handles run under the name "SettlementGuru" or any other such names operated and controlled by the defendant no.1 on various platforms such as Instagram, YouTube, and X.
c) The defendant no.1 is restrained from using in any manner whatsoever, the plaintiff's registered Trademarks "Bajaj Finance" having TM No.1665234 and No.1665235 and other registered device marks containing the words "Bajaj" or "Bajaj Finance" inter alia, such as "
" having TM No.5944516, " " having TM
No.5944517, " " having TM No.5944518 and "
" having TM No.5944519, " " having
TM No.5959017, " " having TM
CS (COMM) 63/2026 Page 11 of 13
This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 No.5944520 and " " having TM No.5959019.
d) The defendant nos.1 to 5 are directed to take down and/or remove the URLs/weblinks aforementioned in para 22, forthwith.
28. Let the plaintiff comply with the requirements of Order XXXIX Rule 3 of CPC within one week from today.
29. Issue notice to the defendants upon filing of the process fee within one week from today. Reply be filed within four weeks. Rejoinder thereto be filed thereto within a week thereafter.
30. List along with CS(COMM) 63/2026.
CS(COMM) 63/2026
31. In view of the facts narrated in I.A. No.1851/2026 and the observations made therein, let the plaint be registered as suit.
32. Issue summons of the suit by all permissible modes upon filing of the process fee within one week.
33. Written statements accompanied by affidavit of admission and denial of the documents of the plaintiff be filed by the defendants within 30 days with an advance copy to the learned counsel of the plaintiff, without which the written statements shall not be taken on record.
34. The plaintiff is permitted, if so required, to file replications thereto accompanied by affidavit of admission or denial of documents of the defendants, within 30 days from date of service, without which the replications shall not be taken on record
35. Learned counsel appears on behalf of defendant no.3 i.e. "X Corp." and submits that on account of the advance notice of the Suit plaint served upon the defendant no.3, the account belonging to defendant no.1 already stands CS (COMM) 63/2026 Page 12 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07 suspended and as such, there is no further requirement of defendant no.3 to be arrayed as a party respondent to the present Suit. Learned counsel for the plaintiff has no objection to the same.
36. Accordingly, defendant no.3 stands deleted from the array of parties. Amended memo of parties be filed by the plaintiff within one week from date.
37. Learned counsel for defendant no.4 appears and accepts advance notice.
38. List before the Joint Registrar (Judicial) for completion of the pleadings, admission and denial of documents and marking exhibits on 30.03.2026.
39. List before the Court on 06.07.2026.
TUSHAR RAO GEDELA, J JANUARY 22, 2026 Sumit CS (COMM) 63/2026 Page 13 of 13 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/01/2026 at 20:34:07