Delhi High Court: In an application filed under Order 39, Rules 1 and 2 of the Civil Procedure Code, 1908, wherein the plaintiff, Sri Sri Ravi Shankar sought protection of his Personality Rights, the Single Judge Bench of Manmeet Pritam Singh Arora, J, granted a John Doe injunction in favor of Ravi Shankar restricting Defendant 1 from creating and disseminating AI generated videos of the plaintiff.
Background
The plaintiff, Sri Sri Ravi Shankar is a globally revered humanitarian leader, spiritual teacher and the founder of ‘The Art of Living’ foundation. Through the ‘World Culture Festival’, he has achieved an unparalleled cultural impact, creating a platform that unites people across continents in shared celebration of art, heritage and human values. He is also the recipient of the Padma Vibhushan and over 26 honorary doctorates for contributions to peace, education and humanitarian service as well as the highest civilian awards in several countries.
The plaintiff is highly renowned for developing innovative breathing and mediation techniques (notably ‘Sudarshan Kriya’) and and simplifying complex philosophical concepts into practical teachings. He has earned immense goodwill through his spiritual guidance, humanitarian service, and unique personal attributes.
The plaintiff had averred that Defendant 1 (John Doe) had been circulating deepfake videos of the plaintiff which depict the plaintiff promoting alleged Ayurvedic remedies for serious health conditions such as haemorrhoids, diabetes and chronic knee pain, rife with exaggerated and unfounded claims for instant and immediate cures for serious ailments. These videos, posted on Facebook (Defendant 4) further claim that the plaintiff had conducted years of research or that he had discovered these remedies during meditation.
The plaintiff had further submitted that his personality, reputation, name, voice, image, likeness and manner of speech were all part of his distinct identity as ‘Gurudev’, ‘Guruji’, ‘Sri Sri’, and ‘Sri Sri Ravi Shankar’. He averred that the attributes of his personality are of considerable value and any unauthorised use amounted to a violation of his Personality Rights under Article 19(1)(a) and 21 of the Constitution.
Analysis, Law and Decision
The Court held that the material on record made it evident that Defendant 1 was circulating deep fake contents unauthorizedly using the name, voice, facial expressions, persona and likeness of the plaintiff.
Thu, the Court held that a prima facie case was made out in favor of the plaintiff as the balance of convenience was in his favor and irreparable harm would be caused to him if the injunction was not granted.
Accordingly, the Court restrained Defendant 1 and all persons acting on its behalf from infringing the plaintiff’s Personality Rights by misappropriating the name ‘Ravi Shankar’ or ‘Sri Sri Ravi Shankar’ or any other aspect of his persona that is exclusively identifiable with him for any personal or commercial use/gain.
The Court directed Defendant 2, Department of Telecommunication and Defendant 3, Ministry of Electronics and Information Technology to issue necessary notifications for blocking all infringing websites.
The Court further directed Defendant 4 to remove/disable access to specific pages, URLs, profiles, accounts, photos or videos publishing any morphed and infringing content, text, social media groups and channels within 36 hours.
The matter was further listed for 19-2-2026.
[Ravi Shankar v. John Doe, CS(COMM) No. 889 of 2025, decided on 26-8-2025]
Advocates who appeared in this case:
For the Plaintiff: Nikhil Sakhardande, Sr. Adv., Ms. Pooja Tidke, Mr. Pranav Sarthi, Mr. Ashish Venugopal, Ms. Apoorva Singh, Ms. Prachi Dhingra, Advocates
For the Respondent: Chetanya Puri, SPC, Mr. Anand Awasthi, Ms. Nisha Puri, Advocates for D-2 and 3. Mr. Varun Pathak, Mr. Yash Karunakaran, Mr. Tanuj Sharma, Advocates for D-4.
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