Summary
In the case of Eternal Sunshine Productions Pvt. Ltd. vs Vedika Prakash Shetty, the Bombay High Court granted an ex-parte ad-interim injunction restraining a former personal secretary from disclosing confidential and personal information of actor Ms. Alia Bhatt. The court held that the employee was contractually bound to maintain confidentiality under the terms of a release letter, and recognised the urgency of protecting sensitive personal data from public exposure.
Background
Employment Confidentiality Dispute
Eternal Sunshine Productions Pvt. Ltd. employed the Defendant, Ms. Vedika Prakash Shetty, as a personal secretary to Ms. Alia Bhatt. Her services were terminated by a Release Letter dated 5 September 2024, which included explicit confidentiality obligations. These obligations barred her from disclosing any confidential or personal information related to the company, its directors, and particularly Ms. Alia Bhatt.
Following the termination, an FIR was lodged, leading to the Defendant’s arrest and custody until 8 September 2025. On her release, the Plaintiff feared imminent disclosure of confidential data and approached the court for an urgent ex-parte injunction.
Questions Before the Court
- Whether the Defendant could be restrained from disclosing confidential and personal information under the terms of the Release Letter.
- Whether the urgency of potential disclosure justified granting an ex-parte ad-interim injunction without hearing the Defendant.
Arguments Presented By the Plaintiff
- The Defendant had access to highly sensitive personal data, including details of Ms. Alia Bhatt and her family.
- The Release Letter contained a detailed confidentiality clause that survived termination.
- The Defendant had already sent a legal notice disclosing certain personal details of Ms. Bhatt.
- Her release from custody posed an imminent risk of further disclosures, potentially to media outlets or social media.
- Issuing notice would cause delay and defeat the purpose of protecting the Plaintiff’s rights.
Court’s Analysis
Court’s Analysis of Confidentiality Obligations The court observed that the Defendant, in her role as personal secretary since May 2021, had access to confidential information and personal details relating to the Plaintiff and its directors, including Ms. Alia Bhatt.
The court cited the Release Letter dated 5 September 2024, particularly Clause 5, which defined “Confidential Information” to include:
- Intellectual property of the client
- Financial information
- Medical history and conditions
- Family dynamics and relationships
- Passwords and personal records
- Any non-public or sensitive information about the client or their associates
The court noted that these confidentiality obligations were explicit, comprehensive, and stated to survive termination in perpetuity. The court further noted that the Defendant had certified return and deletion of confidential data, acknowledging her continuing obligations.
Justification for Granting Ex-Parte Relief The court stated that the Defendant’s release from custody on 8 September 2025, after being arrested for her conduct, presented a serious risk of disclosure.
According to the court:
- Delay in issuing an injunction could lead to irreparable harm to the Plaintiff and Ms. Bhatt.
- Disclosure of personal data could not be adequately compensated in monetary terms.
- An ex-parte injunction was justified under the Proviso to Rule 3 of Order XXXIX of the Code of Civil Procedure, 1908, given the urgency.
- The balance of convenience heavily favoured the Plaintiff.
The court held that the confidentiality clause in the Release Letter was binding and enforceable, and that protecting the personal and private data of individuals was of paramount importance.
Findings
The court granted an ex-parte ad-interim injunction restraining the Defendant from:
- Disclosing or publishing any confidential or personal information of the Plaintiff or its directors
- Communicating any such data to third parties, including media or social media platforms
The injunction will remain in force until further orders, and the Defendant was given liberty to apply for variation after providing 48 hours’ notice.
Relevant Paras
Para 6: “Defendant in her capacity as Personal Secretary appears to have gained knowledge about personal details and confidential information…”
Para 7: “…a case is made out for grant of ad-interim injunction without issuing notice to the Defendant as per the Proviso to Rule 3 of Order XXXIX…”
Para 8: “Plaintiff and its directors would suffer irreparable loss if ad-interim injunction is not granted…”
Para 9: “There shall be ad-interim relief in terms of prayer clause (a)… restraining the Defendant… from disclosing… any Confidential Information including… personal, private and non-public information concerning… Ms. Alia Bhatt…”
Case Citation
Eternal Sunshine Productions Pvt. Ltd. vs Vedika Prakash Shetty, Interim Application (L) No. 27500 of 2025 in Suit (L) No. 27468 of 2025, Bombay High Court, decided on 9 September 2025.
https://indiankanoon.org/doc/44020045/ (Visited on 21 September 2025)
Disclaimer
This case blog is based on the author’s understanding of the judgment. Understandings and opinions of others may differ. An AI application was used to generate parts of this case blog. Views are personal.
