Clear Example Of Personality Rights Infringement: Delhi High Court Grants Dynamic+ Injunction In Favor Of Sadhguru Against AI Doctored Content Floating Online

An application was filed before the Delhi High Court seeking a temporary injunction against the defendants and their associated persons by restraining them from infringing upon the personality and publicity rights of the plaintiff 1- Sadhguru i.e. name, likeness, image, voice, and any other aspects of his persona which are solely and exclusively associated with the plaintiff.

The Single Bench of Justice Saurabh Banerjee said, “In these circumstances, the present case appears, prima facie, to be a clear example of personality rights infringement by entities such as defendant nos. 1-41, who are using modern technology to hide their identities while unlawfully benefiting from the plaintiff’s personality rights.”

“All the above call for this Court to pass a ‘dynamic+’ injunction, a form of injunctive relief which is being granted by Court(s) in similar matters in recent years, primarily with a view to protect parties like the plaintiffs herein against rapidly developing online infringement platforms”, it further added.

Advocate Srikrishna Rajagopal represented the Plaintiffs while Advocate Mamta R. Jha represented the Respondents.

Factual Background

As per the pleadings, plaintiff 1 (Sadhguru) is a globally revered spiritual leader/ yogi/ mystic/ public figure with millions of followers across the globe and has been preaching yoga and spirituality since 1984. The plaintiff 2 (Isha Foundation) is a non-profit trust established by him for disseminating spiritual knowledge and teaching yoga/ meditation to people across the globe, both physically and via the internet. It was averred that the plaintiffs first became aware of the infringing activities in December 2024. These activities include unlawful usage of the plaintiff’s personality rights by the defendants, which are ‘rogue websites’ (primary defendants). The said infringing activities have been executed by creating, uploading, publishing, streaming online content by using modern technology and AI tools to unauthorizedly morph and doctor the plaintiff's voice and discourses/ speeches/ interviews to create deep fakes, misleading and unlawful images, audio-visual advertisements/ videos (impugned content).

It was further noticed that the impugned content is aimed at perpetuating a financial scam by initiating commercial transactions and/or promoting and selling purported services for gaining traction on social media through AI-generated motivational and inspirational talks purported to be originating from Sadhguru.

Reasoning

The Bench noted that the plaintiffs are internationally recognized and identified for their works, their image. The first plaintiff, Sadhguru, has acquired uniqueness pertaining to his personality qua his voice, name, signature, image/ likeness, vocal/ articulation style and his unique attire/ looks/ appearance. “The personality rights of the plaintiff are quite unique, that the plaintiffs easily came across various parties that are unauthorizedly using impugned contents on various internet platform to capitalize on the personality rights of the plaintiff no.1. The same has to be seen from a perspective since the plaintiffs, especially the plaintiff no.1 are/ is present on the social media websites as also in the audio-visual form(s) and print form(s)”, it said.

The Bench took note of the fact that the impugned contents herein not only utilize the plaintiff’s personality rights but the primary defendants went a step further and employed modern-day technology to modify the images, voice, likeness, videos, etc., for commercial gains. It was further noticed that many accounts on YouTube channels and Meta’s social media platforms have been using modern-day technology to modify the voice, image, likeness, etc. of the plaintiff to garner more views and subscribers to piggyback on his name and reputation.

“If allowed to continue in the manner it will soon spread like a pandemic with wide uncontrollable repercussions, especially, since it is a social media platform(s) herein happen to be the internet portal(s). If not stopped, the chances that (wrong) message will spread like wild fire with hardly any water left to douse it”, it noted. The Court was of the view that, given the plaintiff’s unique position as a trusted source for spiritual guidance worldwide, any misrepresentation of his endorsement risks irreparable damage not only to his reputation but also to public trust at large.

The Bench thus injuncted the defendants and the associated persons from using or exploiting Sadhguru’s name, image and likeness, voice, and any other aspects of his persona which are solely and exclusively associated and identified with him for any commercial and/or personal gain, including use through any Artificial Intelligence technology.

Cause Title: Sadhguru Jagadish Vasudev & Anr. v. Igor Isakov & Ors (Case No.: CS(COMM) 578/2025)

Appearance

Plaintiffs: Advocates Srikrishna Rajagopal, Disha Sharma, Deepika Pokharia, Angad Makkar, Pushpet Ghosh

Defendants: Advocates Mamta R. Jha, Mr. Rohan Ahuja, Shruttima Ehersa, Rahul Choudhary, Himani Sachdeva, Sandeep Kumar Mahapatra, Tribhuvan

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