'Dushta IPS': Karnataka HC Confirms 'Power TV' MD Breached Injunction, Reduces Jail Term To 1 Day

In a significant order concerning the 'Dushta IPS' broadcast, the Karnataka High Court last week reduced Kannada news channel 'Power TV' Managing Director Rakesh Sanjeeva Shetty's civil prison term from three months to one day.

The Court also directed the channel to broadcast an on-air apology expressing regret for violating the Court's order, after confirming the finding that it had willfully violated the interim injunction protecting the senior IPS officer's reputation.

Justice K.S. Hemalekha held that top corporate executives in control of a media channel cannot evade liability under Order XXXIX Rule 2A of the Code of Civil Procedure (CPC) by simply passing the buck to their editorial teams.

The Court observed that Parliament deliberately used the word ‘person’ instead of ‘party’ in Order XXXIX Rule 2A to ensure litigants cannot circumvent court orders through persons who are not formally arrayed as parties.

What is the dispute all about?

The dispute arose from a permanent injunction suit instituted by senior IPS officer Dr. B.R. Ravikanthegowda against multiple media platforms, including news channel 'Power TV'.

On September 8, 2023, a trial court granted an ex-parte temporary injunction restraining the defendants from broadcasting or publishing any defamatory material damaging the officer's reputation.

Despite having full knowledge of the interim injunction order's subsistence, 'Power TV' aired programmes on September 22 and 23, 2023, targeting the officer.

The channel broadcast segments branding him as a “Dushta IPS Adhikari” (evil/corrupt IPS officer), displaying his photograph in police uniform alongside tickers alleging extortion, harassment and running a settlement gang.

Following an application filed by the officer under Order XXXIX Rule 2A CPC, the trial court, on January 6, 2026, found the channel guilty of violating the court injunction and sentenced its Managing Director, Rakesh Sanjeeva Shetty, to three months' imprisonment in civil prison.

Principal Senior Civil Judge Abdul Saleem of the Bengaluru Rural District Court concluded that Shetty, representing Power Smart Media Private Limited, knowingly defied the interim temporary injunction and broadcast programmes portraying the police officer in a derogatory manner.

Shetty subsequently challenged the order before the High Court.

What did the High Court observe?

Before the High Court, the appellant argued that, as Managing Director, he could not be held personally liable for day-to-day corporate telecasts or editorial decisions.

Justice Hemalekha rejected this contention, holding that the legislature deliberately chose the word "person" instead of "party" in Order XXXIX Rule 2A to give the provision a wider amplitude, ensuring corporate heads cannot circumvent court orders through internal structural arrangements or proxies.

The Court highlighted that the Managing Director had signed the channel's written statement, actively participated in the trial court proceedings, and even appeared on-screen during the broadcast in question.

It further noted that the Managing Director had himself verified the written statement, sworn affidavits and led evidence before the Trial Court, making it untenable for him to later disclaim responsibility.

The Court observed: "Once the injunction order is directed against the entity, the person in control and responsible for its functioning shall fall within the ambit of the expression 'person guilty of disobedience".

Press Freedom vs Right to Reputation

The High Court emphasised that while freedom of the press under Article 19(1)(a) of the Constitution is an essential component of democratic governance, it is not absolute and must be balanced against an individual's right to reputation under Article 21.

The Bench observed that a subsisting judicial order must be obeyed in both letter and spirit. It held that if the appellant believed the injunction required clarification or permitted reporting of particular material, the proper course was to approach the Court for clarification or modification rather than unilaterally interpret the order and proceed with the telecasts.

The Court further observed that judicial orders cannot be rendered ineffective through unilateral interpretation or selective compliance by parties.

Rejecting the channel's justification that the programmes were based on complaints received by it and formed part of journalistic reporting, the Court held that the appellant had failed to demonstrate any valid justification for telecasting material in violation of the injunction order.

High Court’s order

While dismissing the appeal and affirming the finding of willful disobedience, the High Court modified the three-month sentence to one day in civil prison.

The benefit of the reduced sentence is subject to the channel complying with the following directions:

• Affidavit of Undertaking: The Managing Director must file an undertaking before the Trial Court within two weeks, promising strict compliance with the interim injunction order.

• On-Air Apology: The channel must broadcast a statement apologising for the earlier telecasts and expressing regret for violating the Court's order, within two weeks, and place the broadcast material before the Trial Court.

• Costs: The appellant must pay ₹50,000 as costs to the respondent-officer within four weeks.

The High Court clarified that if the channel fails to comply with any of these conditions, the benefit of the modified sentence would stand withdrawn and the Trial Court's original order directing three months' civil imprisonment would automatically revive.

The Court also directed the Trial Court to proceed with the pending civil suit expeditiously in accordance with law.

Case Title: Power TV v. Dr. B.R. Ravikanthegowda

Date of Judgment: July 10, 2026

Bench: Justice K.S. Hemalekha