It was the seventh over of the Indian innings with medium-pacer Kyle Jarvis being the bowler. Kohli attempted to go past the mid-wicket but Malcolm Waller caught the ball.
The Indian batsman stood his ground even as Waller sought a review from the umpire as the fielder himself was not sure whether he had caught the ball cleanly.
The third umpire adjudged Kohli out even though the replays were unclear.
The 24-year-old, who had scored 14 runs at that stage, went back to the pavillion visibly upset with the decision. He faced 18 deliveries during his stay at the crease and struck a couple of fours.