v) There are no extreme circumstances, that require a global injunction order to be passed; vi) The order to be passed by the Court has to be proportionate to the danger or harm that is alleged. There is greater harm in passing a global injunction order in such circumstances; vii) The publisher of the book has also not been impleaded in the present case and no effective order can be passed in the absence of the publisher; viii) The Defendants are intermediaries and cannot be compelled to run foul of the law in jurisdictions such as the U.S. where they are headquartered. 12. He further submits that a global ban on content ought to be the last resort of the Court. Such an order results in muzzling dissent. Reliance is placed on the Equustek litigation, wherein an order to remove content was passed by the Courts in Canada and when Google brought an action before a US District Court to prevent enforcement of the Canadian Court‟s order, the U.S. Court restricted the application of the Canadian court‟s order only to Canadian territory. Such judgments could severely undermine the dignity of Indian courts if global injunction orders are passed. He relies upon the judgment of the Supreme Court of New York County in Ajitabh Bachchan v India Publications 154 Misc. 2d 228 (N.Y. Misc 1992) decided on 13th April, 1992 to support this argument. Further reliance is placed on the judgment of the Supreme Court of New South Wales in Macquarie Bank Ltd. & Anr. v. Berg [1999] NSWSC 526. Reliance is also placed on the opinion of the Attorney General of the Court of Justice of the EU given in the case of Google Inc. v. CNIL Case C-507/17. Since public interest differs CS (OS) 27/2019 Page 8 of 76