Complainant Mishra told the court that while googling "top ten criminals of the world", the search engine shows an image of Modi. According to Times of India, the advocate had initially requested Google to remove it, but got no response. He also claimed to have approached the police. He then filed an application before the chief judicial magistrate, but his plea was dismissed on November 3, 2015, on the grounds that it was a civil case. Mishra then went on to challenge the order and filed a revision application in court.
Modi's image appeared along with those of underworld don Dawood Ibrahim, slain al-Qaeda chief Osama bin Laden, Hafiz Sayeed, and Ayman al-Zawahiri among others. According to Financial Express, Google is already fighting multiple such cases across the world. The matter had sparked a controversy in June last year after which Google issued an apology statement, saying that the image appeared because of a British daily that had an image of Modi and erroneous metadata. According to Dawn, the images appeared with a disclaimer, "These results don’t reflect Google’s opinion or our beliefs; our algorithms automatically matched the query to web pages with these images."

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