The Delhi High Court on February 17, 2026, declined to entertain a writ petition seeking a ban on the continued streaming of the film Lady Chatterley’s Lover on an OTT platform, holding that the petitioner must first avail the statutory grievance redressal mechanism under the Information Technology Rules, 2021.
- Case Title: Raj Kumar v. Union of India & Anr.
- Court: High Court of Delhi at New Delhi
- Case No.: W.P.(C) 2271/2026
- Bench: Justice Purushaindra Kumar Kaurav
- Date of Judgment: February 17, 2026
Delhi High Court on Lady Chatterley’s Lover OTT Streaming Challenge
The petition was filed by Raj Kumar, appearing in person, challenging the continued publication and streaming of the film Lady Chatterley’s Lover in India on the platform of Respondent No. 2.
The petitioner alleged that the content was obscene and violated constitutional protections under Article 21 of the Constitution of India.
Justice Purushaindra Kumar Kaurav, however, disposed of the writ petition, granting liberty to the petitioner to approach the appropriate grievance redressal body under the three-tier self-regulation mechanism prescribed by the Information Technology Act, 2000, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
Case Background: Obscenity Allegations and Article 21 Claim
According to the order, the petitioner personally accessed the impugned film at his residence. He claimed that it was inadvertently exposed to his family members, including minor children, causing
“mental distress and intrusion into his right to privacy, dignity, and peaceful enjoyment of home under Article 21 of Constitution of India.”
The petitioner contended that the film contained “excessively graphic sexual scenes, frontal nudity, and explicit acts” which, taken cumulatively, were “obscene, pornographic, and offensive to contemporary community standards,” allegedly exceeding permissible limits under Indian law.
He further stated that he had made complaints to multiple authorities regarding the streaming of the film.
IT Rules, 2021 and the Three-Tier Self-Regulation Mechanism
A key aspect of the High Court’s reasoning was the availability of the statutory grievance redressal framework under the Information Technology Act, 2000 read with the IT Rules, 2021.
The Court noted that despite making various complaints, the petitioner had not resorted to the “three-tier self-regulation mechanism” established under the IT Rules, 2021.
At the outset, counsel appearing for Respondent No. 2 submitted that while the Bombay High Court in AGIG Promotion of Nineteenonea Media Pvt. Ltd. & Ors. v. Union of India (WP(L) No. 14172 of 2021) had stayed the three-tier self-regulation mechanism, the stay related specifically to challenges made by operators of digital news portals.
It was further submitted that OTT platforms such as Respondent No. 2 were continuing to adhere to the three-tier self-regulation framework under the IT Rules, 2021.
The Court took this statement on record.
Respondent’s Stand
The respondent’s counsel also informed the Court that, pursuant to a communication dated November 22, 2025, the petitioner’s objections had been duly considered.
It was stated that the contents of the film did not violate the IT Rules, 2021 or any other applicable law.
The communication further conveyed that if the petitioner had any subsisting grievance, he could approach the Grievance Redressal Board of the Digital Publishers Content Grievance Council, which constitutes Tier-2 of the self-regulatory mechanism.
It was also submitted before the Court that the said Council was fully functional and chaired by a former judge of the Supreme Court of India.
Delhi High Court’s Observations and Final Directions
After recording the submissions, the Delhi High Court observed that in view of the availability of the grievance redressal mechanism, the petitioner should approach the concerned Council.
The Court granted liberty to the petitioner to do so and observed that if he availed the mechanism,
“there is no doubt that his grievance could not be taken to its logical conclusion.”
With these observations, Justice Purushaindra Kumar Kaurav disposed of the writ petition.
No interim relief was granted against the continued streaming of the film.
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