TV Today Network Limited v. Union of India

Delhi High Court · 01 Dec 2022 · 2022:DHC:5409
Prathiba M. Singh
W.P.(C) 1971/2021
2022:DHC:5409
administrative petition_dismissed Significant

AI Summary

The Delhi High Court upheld the Ministry's finding of surrogate advertising but modified the penalty and recognized the new statutory grievance redressal mechanism under the 2021 amendments, disposing of the writ petition.

Full Text
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2022/DHC/005409
W.P.(C) 1971/2021
HIGH COURT OF DELHI
Date of Decision: 1st December, 2022
W.P.(C) 1971/2021
TV TODAY NETWORK LIMITED ..... Petitioner
Through: Mr. Arunabh Chaudhary, Sr.
Advocate with Mr. Shahrukh Ejaz and Mr. Karma Dorjee, Advocates
(M: 7838390214).
VERSUS
UNION OF INDIA ..... Respondent
Through: Ms. Monika Arora, Mr. Yash Tyagi, Mr. Subhrodeep, Advocates (M-
CORAM:
JUSTICE PRATHIBA M. SINGH Prathiba M. Singh, J.(Oral)
JUDGMENT

1. This hearing has been done through hybrid mode.

2. The challenge in this case rests on the distinction between club soda and whisky. For persons who consume the same, the distinction is quite clear! However, in the case of advertisements which are alleged to be surrogate, the lines are blurred.

3. This petition has been filed on behalf of the Petitioner – T.V. Today Network Ltd. challenging the impugned order bearing no. N-4l011/27/2020- BC.III dated 9th February, 2021 by which the Respondent – Union of India, Ministry of Information & Broadcasting has directed the Petitioner to run an apology scroll in bold legible font at the bottom of the screen for two days continuously, with effect from 0001 hours on 16th February, 2021 to 0001 hours on 18th February, 2021. The operative portion of the order reads as under: “.. WHEREAS the Competent Authority, having considered all the facts and circumstances of the case, including the recording, the written submission of Aaj Tak TV channel, the recommendations of the IMC, the provisions of the Cable Television Networks (Regulation) Act, 1995 and the Rules framed thereunder, has come to a conclusion that there was a clear violation of Rule 7(2)(viii)(A) of the Advertising Code. NOW, THEREFORE, having regard to the totality of the circumstances, as explained above, the Competent Authority in the Ministry of Information & Broadcasting, hereby directs Aaj Tak TV channel to run an Apology Scroll in bold legible form at the bottom of the screen for two days continuously with effect from 0001 hours on 16.02.2021 till 0001 hours on 18.02.2021. Strict compliance with the above direction will be ensured by Aaj Tak IV channel …”

4. As per the impugned order passed by the Respondent, the Petitioner ran an advertisement of “All Seasons” Club Soda which was a surrogate advertisement for “All Seasons” Whisky, sold in a similar bottle and layout. The telecast of the advertisement took place during the LIVE coverage of the Independence Day event. The footage which was shown to the Court shows that in the said live telecast, an ‘L’ shaped advertisement was broadcast on the `Aaj Tak’ TV channel, which, according to the Petitioner, relates to the “All Seasons” Club soda product. The Ministry of Information and Broadcasting (hereinafter, ‘I&B Ministry’), however, found the same objectionable in terms of the provisions of the Cable Television Networks (Regulation) Act, 1995 and issued a show cause notice on 7th September,

2020. Reply to the said notice was also filed by the Petitioner. After hearing the Petitioner, the I&B Ministry came to the conclusion that the colour and layout of the bottle being the same as the whisky bottle of the advertiser, the advertisement is nothing but surrogate advertising and hence, the direction to issue an apology was imposed.

5. This petition was listed before this Hon’ble Court on 15th February,

2021. After hearing the submissions made by the parties, considering the video advertisement footage, as also the notice replied in the impugned order, the Court had passed an order in the following terms:

“8. The Cable Television Network Rules, 1994, stipulate under Rules 6 and 7 the `Programme Code’ and `Advertising Code’. However, the consequences of violation thereof, are not clearly provided for. The matter thus requires consideration. 9. At this stage, the Court is only looking at what the interim relief, if any, ought to be granted considering that the apology has to be shown by the Petitioner from tonight from 0001 hours. Admittedly, there are no clear regulations as to the extent of penalty and punishment that can be imposed in case an advertisement is found to be objectionable and violative of the `Advertising Code’. 10. The counsel for the Petitioner has, during the video-conference hearing, exhibited the bottle used by the advertiser for Club Soda and Whisky. From a first look at the same, they appear very similar. The fact that the Whisky bottle and the Club Soda bottle used, have the same look and feel/trade dress, this Court is of the opinion that the entire order cannot be interdicted and stayed. The identity between the two product containers and the fact that the Petitioner uses an alternate bottle for its Club Soda, do raise questions relating to `Surrogate advertising’. However, considering that the measure imposed also cannot be disproportionate and keeping in mind that the apology so directed ought not to interfere unreasonably with the normal telecast of the channel, the frequency of the apology and the duration deserves to be curtailed/reduced.
11. Accordingly, at this stage, the Petitioner is directed to run a 10 second apology every hour between 8:00 a.m. to 8:00 p.m. on two days i.e., 16th February, 2021 and 17th February, 2021.
12. CM APPL. 5764/2021 is disposed of in the above terms. Let the counter affidavit to the writ petition be filed within four weeks. Rejoinder be filed within four weeks thereafter. In the counter affidavit, the I&B Ministry shall specifically state if there is any uniform policy followed by it in imposing penalties for violation of the `Programme Code’ or `Advertising Code’.”

6. In view of the aforementioned order dated 15th February, 2021 passed by this Court, the Respondent filed a short affidavit on the question of whether any uniform policy is followed for imposing penalties for violation of the ‘Programme code’ or ‘Advertising code’ (Rules 6, 7 of the Cable Television Network Rules, 1994 ). The said short affidavit states as under:

“8. With regard to the specific query of Hon'ble Court
in Order dated 15.02.2021, as to whether there is any
uniform policy followed by this Ministry in imposing
penalties for violation of the Programme Code or
10,321 characters total
Advertising Code, it is respectfully submitted that for
looking into the cases of violations of Programme and
Advertising Codes, an Inter-Ministerial Committee
(IMC) has been constituted under the Chairmanship of Additional Secretary (I&B) with representatives from
the Ministries/ Departments of Consumer Affairs, Home Affairs, Law & Justice, Women & Child Development, Health & Family Welfare, External Affairs, Defence and a member from Advertising Standards Council of India. The IMC after considering all the facts and circumstances of case including CD recordings of the impugned programme, reply of the channel and gravity of violation, gives its recommendations on the action to be taken against the channel. The penalty recommended by IMC depends upon several factors on case-to-case basis viz., gravity of the violation of the Programme or Advertising Code, the content of telecast programme or advertisement, the time when the largest number of children are viewing etc.. The recommended penalty includes issuance of warnings, advisories, asking channels to run apology scrolls on their channel and off-air order for varying periods. The Ministry takes a final decision on the action to be taken with respect to the channel.”

7. Today, ld. Senior Counsel appearing for the Petitioner, relying on information obtained under the RTI Act, submits that the Petitioner was singled out for running an apology, whereas, similarly placed channels were merely given a warning by the I&B Ministry. This is disputed by ld. CGSC who has placed a note before the Court to state that insofar as the “All Seasons” advertisement was concerned, seven channels were directed to run an apology scroll and two channels had filed writ petitions before this Court. In one of the writ petitions bearing W.P.(C) 10982/2022 titled New Delhi Television Limited v. Union of India & Anr, the ld. Single Judge had directed as under:

“9. Accordingly the writ petition shall stand disposed of with a direction to the petitioner to carry the apology scroll as mandated under the impugned order insofar as the clip relating to “All Seasons” is
concerned. The petition will further run an explanatory scroll that the clip relating to “100 Pipers” came to be broadcast as a consequence of the subsequently discovered misrepresentation of the advertiser. The time slots for running of the aforesaid scrolls shall be as per the impugned order. The impugned order shall stand modified to the aforesaid extent only.”

8. Ld. CGSC further submits that as of June, 2021, the I&B Ministry has introduced amendments through the Cable Television Networks (Amendment) Rules, 2021. As per the said amendments, a statutory mechanism has been put in place for redressal of grievances and complaints of citizens relating to content broadcast of television channels. The said rules provide for a three level complaint redressal structure.

9. Heard and perused the record. Insofar as the objectionable advertisement was concerned, this Court by an interim order had observed after recording various reasons that the apology ought to be given by the Petitioner. However, due to the disproportionate nature of the extent of apology the same was reduced. The apology, as directed by the Court is already stated to have been run by the Petitioner.

10. Coming to the larger question as to whether such an apology could have been directed by the Respondent or not, under the extant Act and Rules, the introduction of the amendments in 2021, would be relevant. As per the amendments made to the Cable Television Networks (Amendment) Rules, 2021 vide notification dated 17th June, 2021 three levels of complaint redressal structure have been provided.

(i) Level I - A self-regulation by broadcasters;

(ii) Level II - Self-regulation by the self-regulating bodies of the broadcasters; and

(iii) Level III - Oversight mechanism by the Central Government.

11. There is no challenge to these amendments in this writ petition. Since a new mechanism and the structure for redressal of grievances and complaints has been put in place, the grounds raised in the petition would no longer survive. It is made clear that this Court has not examined the validity or legality of the amendments of 2021 in this writ petition.

12. Accordingly, the writ petition is disposed of and no further orders are called for in this matter. All pending applications are disposed of.

PRATHIBA M. SINGH JUDGE DECEMBER 1, 2022 Rahul/KT