D.P. Choudhary v Manjulata (1997)

Law of Torts · Defamation

Facts.

A local newspaper published an untrue report that Manjulata, a well-educated young woman of a respectable family, had run away in the night with a boy, on the pretext of attending night classes. Her marriage prospects and reputation were damaged.

Issue.

Was the publication defamatory, and what damages should follow where the imputation strikes at a young woman’s character and marriage prospects?

Held.

The Rajasthan High Court held the imputation plainly defamatory. Being a publication in a newspaper it was libel, actionable without proof of special damage, and the court awarded substantial damages for the injury to her reputation and to her prospects of marriage.

Why it matters.

It is the standard Indian illustration of defamation of character by a press report, and the direct answer to the Oct 2023 “ran away with a boy” problem.

⚠️ Do not cite it for the slander proposition. It is frequently offered in guides as authority that slander is actionable per se in India. The defamatory matter was a newspaper report — libel — so the case decides nothing about slander. For that, cite Hirabai Jehangir v Dinshaw Edulji (1927) and Girja Prasad Sharma v Umashankar Pathak (1972), against the Madras line in Parvathi v Mannar (1884).

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