Delhi High Court Issues John Doe Injunction Safeguarding Sri Sri Ravi Shankar’s Personality Rights Against Deepfake and Morphed Content
Safiya Malik
The High Court of Delhi, Single Bench of Justice Manmeet Pritam Singh Arora, has issued a recent John Doe order to safeguard the personality rights of Sri Sri Ravi Shankar, founder of the Art of Living foundation. The Court restrained unidentified persons from exploiting his name, voice, image, likeness, distinctive style of discourse and delivery, or any other uniquely identifiable attribute for commercial or personal gain without his consent. Citing his constitutional personality and publicity rights, the Court directed Facebook to remove infringing deepfake videos within 36 hours, ordered domain registrars to suspend two offending websites within 72 hours, and asked authorities to block access to them.
The case was brought by Ravi Shankar, globally known as the founder of the Art of Living foundation, against unidentified individuals referred to as John Doe(s)/Ashok Kumar(s) and others. The plaintiff alleged that between July and August 2025, unknown persons circulated fabricated videos using advanced AI tools, including deepfake technologies, on Facebook and other websites. These videos falsely depicted him endorsing Ayurvedic and natural remedies for serious ailments such as haemorrhoids, diabetes, and chronic knee pain, accompanied by exaggerated claims of instant cures. The plaintiff stated that these acts infringed his personality and publicity rights by misappropriating his name, voice, image, likeness, and unique style of discourse, which he claimed were integral to his public identity.
The plaintiff sought a permanent injunction to restrain such unauthorized use, alleging violation of his constitutional rights under Articles 19(1)(a) and 21. The plaint also requested discovery and disclosure of subscriber and registrant details associated with the offending accounts and websites.
The Court heard applications under various provisions, including Section 12A of the Commercial Courts Act, 2015 for exemption from pre-institution mediation; Order I Rule 10 CPC for impleadment of two domain name registrars; and Order XI Rules 1, 3, and 5 CPC for discovery and disclosure. The plaintiff submitted an affidavit detailing the URLs, transcripts, and descriptions of twelve deepfake videos. The Court noted that Facebook, the concerned social media platform, and certain domain registrars and government departments were made parties for compliance with interim reliefs.
The Court observed that “defendant no. 1 (John Doe) is circulating deepfake contents unauthorizedly using the name, voice, facial expressions, persona and likeness, of the plaintiff.” It further recorded that “a prima facie case is made out in favour of the plaintiff and against the defendant no. 1. Balance of convenience is also in favour of the plaintiff, and irreparable harm will be caused to the plaintiff, if defendant no. 1’s are not restrained to publish/circulate the deepfake contents.”
In recognizing the plaintiff’s rights, the Court noted that he is “widely recognized by names such as ‘Gurudev’, ‘Guruji’, ‘Sri Sri’, and ‘Sri Sri Ravi Shankar’; his personality, reputation, and distinct identity are intrinsically linked to his name, voice, image, likeness, and manner of speech.” The Court recorded that “these elements constitute his judicially recognized ‘personality rights’ and ‘publicity rights’ under Articles 19(1)(a) and 21 of the Constitution of India.”
The Court also took note of the plaintiff’s exclusive control over the commercial and non-commercial use of his identity attributes, stating that “any unauthorized use, including digitally manipulated ‘deepfake’ content, amounts to a violation of his rights.” On this basis, it found it appropriate to grant interim protection.
Further, the Court allowed impleadment of two domain registrars as defendants to facilitate compliance with its directions and granted exemption from pre-institution mediation due to the urgency of the matter. The Court also required disclosure by Facebook and the domain registrars of details of the entities responsible for the infringing content.
The Court ordered that “defendant No. 1… and all other persons are restrained from infringing the plaintiff’s personality rights and publicity rights by utilizing and/or in any manner directly and/or indirectly using or exploiting or misappropriating the plaintiff’s (a) name ‘Ravi Shankar’ or ‘Sri Sri Ravi Shankar’ (b) voice; (c) image; (d) likeness; (e) unique style of discourse and delivery; and/or (f) any other attribute… without the plaintiff’s consent and/or authorization.”
“Defendant No. 4… remove/disable access to the specific pages… within 36 hours,” and that “defendant Nos. 5 and 6… lock and suspend the domains… within 72 hrs… and disclose all registrants’ details.”
The Court also directed government authorities to block access to the specified websites.
Advocates Representing the Parties
For the Petitioner: Mr. Nikhil Sakhardande, Senior Advocate; Ms. Pooja Tidke; Mr. Pranav Sarthi; Mr. Ashish Venugopal; Ms. Apoorva Singh; Ms. Prachi Dhingra, Advocates
For the Respondents: Ms. Chetanya Puri, Senior Panel Counsel; Mr. Anand Awasthi; Ms. Nisha Puri, Advocates; Mr. Varun Pathak; Mr. Yash Karunakaran; Mr. Tanuj Sharma, Advocates
Case Title: Ravi Shankar v. John Doe(s)/Ashok Kumar(s) & Ors.
Case Number: CS(COMM) 889/2025
Bench: Justice Manmeet Pritam Singh Arora
