Delhi High Court Upholds Interim Injunction Against Geeta Publishing House Over Subhash Dey Books

The Delhi High Court has recently upheld a District Judge's refusal to vacate an interim injunction restraining Geeta Publishing House from publishing, selling, revising, editing, circulating, or advertising Subhash Dey's Business Studies books for Classes XI and XII, or any other books authored by him.

It held that the dispute over whether the publishing agreement was validly terminated must be decided at trial.

“Further, it is not the plea of Mr Wason that the memorandum of agreement is not terminable. In that sense, whether the memorandum of agreement has been rightly terminated or not needs to be decided in the suit, after trial,” the court said.

A Division Bench of Justices V. Kameswar Rao and Manmeet Pritam Singh Arora also noted that the suit had reached an advanced stage, with the plaintiff's evidence scheduled. The court said this was another reason not to interfere with the impugned order.

The bench was hearing Geeta Publishing House's appeal against the District Judge's March 27, 2025 order. That order had dismissed its application seeking vacation of an interim injunction granted on March 6, 2020.

The dispute arises from a memorandum of agreement executed on October 12, 2006 between Geeta Publishing House and Dey. Under the agreement, the publisher obtained exclusive rights to publish his Business Studies books for Classes XI and XII from the academic year 2007-08 onwards.

Dey later purported to terminate the agreement through a legal notice dated December 29, 2019. He then filed a suit seeking a declaration that the publisher had no rights over the books, along with a permanent injunction and rendition of accounts.

In March 2020, the trial court granted an interim injunction. It restrained the publisher from publishing, selling, revising, editing, circulating or advertising the books, or any other books authored by Dey, till further orders.

Before the High Court, Geeta Publishing House argued that Dey had falsely claimed termination of the agreement. It contended that a purchase invoice dated December 26, 2019 showed that Dey himself had breached the agreement even before issuing the termination notice.

The publisher also argued that it had regularly rendered royalty accounts in accordance with the agreement. It said Dey had verified and accepted those accounts. It also claimed that it held the first option to publish any future works authored by him.

Rejecting the appeal, the High Court held that these issues, including the allegations of concealment, breach and the validity of termination, required adjudication at trial. It said they did not justify interference at the interim stage.

The court dismissed the appeal. The interim restraint will continue.

For Appellant: Advocates Vipin Wason, Stuti Wason, and Sanstuti

For Respondent: Advocates Manoj Sharma and Kapil Kaushik