Whether client lists maintained by the Plaintiff, can be deemed proprietary information or trade secrets, deserving legal protection?

  It is important to examine whether such client lists, even if they are maintained by the Plaintiff, can be deemed proprietary information or trade secrets, deserving legal protection. In this Court‟s view, a client list, by itself, is not automatically protected as confidential information simply by virtue of its existence. To be considered a trade secret or confidential information, the list must have economic or business value that requires safeguarding against competitors. {Para 26}

27. The mere existence of a client list does not confer proprietary rights over it in a way that would prevent former employees from using it, unless there is evidence that the list is compiled through proprietary methods, or that it holds specific commercial value that could harm the business if disclosed. It is also essential to distinguish between information that is generally known or accessible in the public domain and information that is truly confidential, which would merit the protection of an injunction.

28. In this context, while a company may claim that its client list is confidential, the Court must scrutinize whether such information is truly proprietary or whether it simply reflects business relationships that are already in the public domain. If the client details are publicly known or easily ascertainable by competitors, it would be unreasonable to grant an injunction based on a claim of confidentiality.

29. Therefore, the issue at hand is not merely whether the Defendant has knowledge of the Plaintiff‟s clients, but whether that knowledge rises to the level of confidential information or trade secrets that can be protected by legal measures such as an injunction. Without clear evidence that the client list holds economic value and that its use would harm the Plaintiff‟s business interests, the Plaintiff‟s request for an injunction based solely on the existence of a client list cannot be sustained.

IN THE HIGH COURT OF DELHI AT NEW DELHI

 C.S. (OS) 1011/2024

 CIGMA EVENTS PRIVATE LIMITED  Vs DEEPAK GUPTA & ORS.

CORAM:

HON'BLE MS. JUSTICE SWARANA KANTA SHARMA

Dated: 24.12.2024.

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