Customer database does not qualify as a trade secret


Delhi High Court recently examined whether a list of customers/clients together with information about their contact persons/numbers maintained by a service provider has copyright.

In Navigator Logistics Ltd v Kashif Qureshi & Ors, the plaintiff, an employer, filed an application for a permanent injunction against eight of its ex-employees and four of its competitors to restrain them from violating and disclosing copyrighted confidential information and trade secrets contained in electronic devices given by the plaintiff to the former employees during the course of their employment. The application further asked that the former employees be restrained from carrying on a similar business and pay damages of ₹15 million (US$210,000) for violation of their employment contracts.

After examining documents, the high court observed that the confidential information was created from client information, which primarily included names, addresses, contact numbers of the clients, customer database, account information, airway drawings, airway bills templates, etc. The court held that such information was purely a mechanical exercise and easily available in the public domain, and thus could not qualify as being a confidential list. Anyone in employment for a period of time would know certain facts and would get to know some information without any special effort, and all such persons cannot be said to know trade secrets or confidential information, and every opinion or general knowledge of facts cannot be labelled as trade secrets or confidential information.

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The dispute digest is compiled by Bhasin & Co, Advocates, a corporate law firm based in New Delhi. The authors can be contacted at or Readers should not act on the basis of this information without seeking professional legal advice.