Delhi High Court: In a petition filed by the plaintiffs seeking permanent injunction for passing off, violation of common law rights, misappropriation of personality, publicity rights etc., Saurabh Banerjee, J.*, stated that the systematic, organised and intentional nature of the infringement, and the regularity and consistency with which the infringed content was being updated/ uploaded on the ‘rogue websites’ showed the extent of the violation of Sadhguru’s rights in real time. Therefore, the Court stated that the plaintiffs had made out a prima facie case in their favour and if an ex parte ad interim injunction was not granted, the plaintiffs would likely suffer irreparable loss and injury. Thus, the Court passed interim injunction in the plaintiffs’ favour.
Background
Plaintiff 1 i.e., Sadhguru, was a globally revered spiritual leader/ yogi/ mystic/ public figure with millions of followers across the globe and had been preaching yoga and spirituality since 1984. Plaintiff 2 (‘Isha Foundation’) was a non-profit trust established by Sadhguru vide trust deed dated 7-1-1992, for disseminating spiritual knowledge and teaching yoga/ meditation to people across the globe, both physically and via the internet. Further, Sadhguru had acquired considerable recognition qua spiritual teachings, projects, books, and overall initiative taken for the betterment of humanity.
The plaintiffs’ counsel contended that in December 2024, the plaintiffs first became aware of the infringing activities, i.e. unlawful usage of the plaintiff’s personality rights by the Defendants 1-41 (‘primary defendants’), which were ‘rogue websites’. The said infringing activities are executed by creating, uploading, publishing streaming online content by using modern technology and AI tools to unauthorizedly morph and doctored the Sadhguru’s voice and discourses/ speeches/ interview(s) to create deep fakes, in the nature of false, misleading and unlawful images, audio-visual advertisements/ videos (‘impugned content’). Further, the impugned content was 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/ speeches purported to be originating from Sadhguru.
Analysis, Law, and Decision
The Court observed that Sadhguru had acquired uniqueness pertaining to his personality with respect to his voice, name, signature, image/ likeness, vocal/ articulation style and his unique attire/ looks/ appearance. The impugned contents were not only utilizing Sadhguru’s personality rights, but the primary defendants had gone a step further and employed modern day technology to modify the images, voice, likeness, videos etc. for commercial gains and pertinently, the primary defendant’s mala fide intent was revealed from the conduct of the primary defendants.
The Court stated that if we allowed to continue in the manner, it would soon spread like a pandemic with wide uncontrollable repercussions. If not stopped, the chances that wrong message would spread like wildfire with hardly any water left to douse it. In any event, it was extremely implausible to ask Sadhguru, to run/ chase after each one of the ‘unknown’ defendants who happen to be ‘rouge websites’ and/ or to respond to the world at large qua the ‘originality’ of the plaintiffs, especially the Sadhguru.
The Court stated that on one hand, though such intellectual property right holders like the plaintiffs could proceed in the normal manner, but, on the other hand, without any proper channelization, their intellectual property rights were prone to get effected by such ‘rogue websites’, who had no right, title and/ or interest. This would lead them and their facilitators to freely and blatantly exploit the personality rights of the plaintiffs, causing irreparable loss, damage and injury to them as also leaving them struggling on the fence exposed dangerous edge of technology.
The Court stated that given the Sadhguru’s unique position as a trusted source for spiritual guidance worldwide, any misrepresentation of his endorsement risks irreparable damage not only to his personal reputation but also to public trust at large. It was submitted that such acts of misrepresentation disproportionately harm Sadhguru, as they strike at the very foundation of his professional standing, which was inextricably linked to public trust. For these reasons, the Court stated that the gravity of the present case extended beyond mere economic considerations and implicated larger issues of public welfare, consumer protection, and the integrity of public discourse.
The Court stated that the systematic, organised and intentional nature of the infringement, and the regularity and consistency with which the impugned content was being updated/ uploaded on the said ‘rogue websites’ showed the extent of the violation of Sadhguru’s rights in real time. Therefore, the Court stated that the plaintiffs had made out a prima facie case in its favour and against the defendants. If an ex parte ad interim injunction was not granted, the plaintiffs would likely suffer irreparable loss and injury.
Thus, the Court restrained Defendants 1-41 and 48, their owners, partners, proprietors, officers, servants, employees, and all others acting for and on their behalf, from using or exploiting Sadhguru’s name, image and likeness, voice, and any other aspects of his persona which were solely and exclusively associated and identified with him for any commercial and/or personal gain and/or in any manner whatsoever without Sadhguru’s express written authorisation, including through the use of any technology such as Artificial Intelligence and in any medium, format or platform, in any manner that amounts to violation of Sadhguru’s personality and publicity rights.
The Court directed Defendant 42 to suspend/ lock/ disable any further websites/domain name as might be subsequently identified the plaintiffs. Further, Defendant 45 was directed to suspend/ takedown/ disable the YouTube accounts/channels, which exclusively pertained to such content infringing upon Sadhguru’s personality rights.
The Court directed Defendants 46 and 47 to issue necessary notifications/ directions calling upon various service providers/ social media platforms to block access/suspend various websites, social media accounts, channels, etc. of the primary defendants or such other websites that might subsequently be notified by the plaintiffs to be infringing their exclusive rights.
The Court further stated that in case, during the pendency of the present suit, the plaintiffs discovered any more false, fabricated and/ or deep fake content not originating from or associated with the plaintiffs, the plaintiffs should be at liberty to approach Defendant 45 requesting them to block/ take down, within 36 hours, any such post/ image/ video/ text/ or any other deep fake content, which was published on its platforms or utilizing its platforms.
The matter is next listed on 14-10-2025.
[Sadhguru Jagadish Vasudev v. Igor Isakov, 2025 SCC OnLine Del 3804, decided on 30-5-2025]
Advocates who appeared in this case :
For the Plaintiffs: Srikrishna Rajagopal, Disha Sharma, Deepika Pokharia, Angad Makkar and Pushpet Ghosh, Advocates
For the Defendants: Mamta R. Jha, Rohan Ahuja, Shruttima Ehersa, Rahul Choudhary and Himani Sachdeva, Advocates; Sandeep Kumar Mahapatra and Tribhuvan, Advocates.
