Delhi High Court Shields Sadhguru from AI-Driven Personality Misuse with "Dynamic+" Injunction | Latest Sadhguru News

The Delhi High Court has issued a significant interim order in the case of Sadhguru, the founder of Isha Foundation, taking decisive action to safeguard his personality and publicity rights from unauthorized exploitation through Artificial Intelligence (AI). This ruling, delivered by Justice Saurabh Banerjee, specifically restrains various rogue websites and unidentified entities from misusing Sadhguru's distinctive personal attributes across any digital medium or platform. The court's decision was an ex-parte interim order, indicating that the balance of convenience heavily favored granting immediate relief to Sadhguru.

A pivotal aspect of this judgment is the issuance of a 'dynamic+' injunction, a form of injunctive relief increasingly employed by courts to counter rapidly evolving online infringement platforms. This mechanism is designed to provide effective protection against the pervasive and often elusive nature of digital piracy and misuse. The court explicitly recognized Sadhguru's unique persona, encompassing his voice, name, signature, image, likeness, vocal articulation style, and distinctive attire or appearance. The infringing content was found not only to utilize these personality rights but also to leverage modern AI technology to modify his images, voice, likeness, and videos for illicit commercial gains.

In response to these infringements, the court issued clear directives, including the suspension and takedown of YouTube channels and accounts exclusively dedicated to violating Sadhguru's personality rights. Furthermore, it mandated the disclosure of basic subscriber information for these infringing entities. The Department of Telecommunications (DoT) and the Ministry of Electronics and Information Technology (MeitY) were also instructed to issue notifications to social media platforms, compelling them to block or suspend websites, accounts, and channels that infringe upon Sadhguru's exclusive rights.

This immediate and broad-ranging interim order, particularly the 'dynamic+' injunction, signals a proactive stance by the judiciary in addressing AI-related challenges, especially given the current absence of dedicated AI legislation in India. The judiciary is not passively awaiting legislative action but is actively adapting existing legal principles and developing new tools to confront rapidly evolving technological threats. This approach fills a critical void and establishes a crucial precedent for how courts may continue to respond to AI misuse before comprehensive laws are enacted. The explicit enumeration of Sadhguru's unique personality traits as protectable assets further underscores an evolving understanding of "personality rights" to encompass a comprehensive "digital identity" in the AI age. This detailed recognition signifies an understanding that AI can mimic not just visual or auditory aspects but also stylistic and characteristic elements that form a public figure's unique persona, expanding the traditional scope of publicity rights and acknowledging the multifaceted nature of digital identity.

Court Gives Sadhguru A "Dynamic+" Injunction In Case Filed By Isha Foundation

The Delhi High Court's interim order in the case of Sadhguru marks a significant moment in the evolving jurisprudence of personality rights in India. The suit was initiated by Sadhguru and the Isha Foundation, targeting a multitude of rogue websites and unknown entities engaged in the unauthorized use of his persona. Justice Saurabh Banerjee presided over the case, issuing an ex-parte interim order that found the balance of convenience to be unequivocally in favor of Sadhguru.

The scope of protection granted by the order is comprehensive, safeguarding Sadhguru's personality and publicity rights and specifically restraining the misuse of his unique traits through Artificial Intelligence across any medium or platform. The court meticulously detailed the specific attributes that constitute Sadhguru's unique personality, including his voice, name, signature, image, likeness, vocal articulation style, and his distinctive attire, looks, or appearance. Justice Banerjee emphasized that these personality rights are "quite unique," underscoring their distinctiveness and commercial value.

The court's decision to grant the interim order was rooted in the imperative that a plaintiff's rights "cannot be rendered otiose" (ineffective) in an era of rapidly developing technology. It stressed that the enforcement of intellectual property rights on social platforms, including the internet, must be "visible and effective" to counter the pervasive nature of online infringement.

Court Acknowledges Sadhguru as a Trusted Global Spiritual Guide

The Court acknowledged Sadhguru as a trusted global spiritual guide with a unique and recognizable personality. Justice Banerjee noted that any misuse or misrepresentation of his persona could severely damage his reputation and erode public trust. The judgment highlighted that the defendants were employing modern technology like URL-redirection and identity masking to unlawfully benefit from Sadhguru's established personality. The Court observed that if such activities were not curtailed, the false messages could spread uncontrollably, causing significant harm.

Concerns of Fake Sadhguru News

The core of the infringement lay in the sophisticated misuse of Sadhguru's persona through modern AI technology. The impugned content not only utilized his personality rights but also employed AI to modify his images, voice, likeness, and videos for commercial gains. Sadhguru's counsel argued that his name was being "completely commercially misused by rogue websites through the use of Artificial Intelligence (AI)". This misuse was characterized as an "out and out case of fraud".

Specific instances of AI-driven misuse detailed during the proceedings included:

• Fake AI-doctored audios, videos, and images circulated on social media to sell products and gain subscribers, leveraging Sadhguru's goodwill and popularity.
• Products being sold with his image, falsely implying endorsement.
• Fake AI-generated videos, morphed images depicting false events such as Sadhguru's arrest, and misleading advertisements promoting financial investments.
• The unauthorized use of his photograph on the cover of a book titled "Garbh Yatra" (on pregnancy), despite Sadhguru having no involvement, leading people to "blindly trust these offerings because of my reputation".
• The fabrication of an entire narrative to drive traffic to an investment platform named 'Trendastic Prism', including conjured newspaper articles.

This explicit mention of AI as the tool for misuse and the detailed description of AI-driven modifications signal a clear judicial understanding that AI-generated content presents a fundamentally different and more dangerous form of infringement than traditional methods. This is not merely an infringement of image rights but a recognition that AI enables a level of realism, scale, and deception that surpasses conventional methods. This implies that the judiciary views AI as a unique threat vector requiring tailored legal responses, laying the groundwork for future AI-specific interpretations or regulations beyond general intellectual property law.

The court's strong language about the misuse spreading "like a pandemic with wide uncontrollable repercussions" underscores not just commercial harm to the celebrity, but also the significant public deception and fraud. The court's concern clearly extends beyond Sadhguru's individual rights to the broader societal impact. By using terms like "pandemic" and "wild fire," the court highlights the rapid, widespread, and potentially irreversible damage that AI deepfakes can inflict on public trust, consumer safety, and the integrity of information. This suggests that future rulings in AI misuse cases may increasingly consider the public interest and consumer protection as key factors, pushing for more stringent platform responsibilities and potentially influencing broader regulatory frameworks.

Key Instances of AI Misuse in the Sadhguru and Isha Foundation Case:

Fake Videos/Audios/Images
AI-doctored content is circulated on social media to sell products, gain subscribers, and leverage goodwill and popularity.

Misleading Advertisements
This includes fabricated arrest visuals and misleading investment promotions, such as those on the 'Trendastic Prism' platform. The aim is to exploit popularity, push products, and commit financial fraud through deception.

Unauthorized Product Endorsement
An example is the use of Sadhguru's image on the "Garbh Yatra" book cover without permission. This misuse is intended for commercial gain, fraud, and leveraging a public figure’s reputation to boost sales.

Impersonation/Fabricated Narratives
Conjured newspaper articles and false statements are used to deceive the public and drive traffic to fraudulent schemes.

The 'Dynamic+' Injunction: A Proactive Judicial Mechanism In Favour of Sadhguru and Isha Foundation

To combat the pervasive nature of these infringements, the court issued a 'dynamic+' injunction. This legal mechanism is designed to extend protection even against unknown future violators, a crucial tool against the "hydra-headed" nature of online piracy. The court noted that such rogue websites, even if blocked or deleted, possess the "incredible potential to resurface in multitudes as alphanumeric or mirror websites, with only minor, mechanical changes". These entities often mask their registration and contact details, making it virtually impossible to locate their operators. The 'dynamic+' injunction allows for greater flexibility in enforcement, enabling plaintiffs to address new infringing websites as they emerge without the need to return to court for each new instance of violation.

Directions to Media and Government on Sadhguru-related Content

The court's order included specific directives aimed at curtailing the spread of infringing content:

• Suspension of accounts and takedown of YouTube channels exclusively pertaining to content infringing Sadhguru's personality rights.
• Disclosure of basic subscriber information from these infringing entities.
• Directives to the Department of Telecommunications (DoT) and the Ministry of Electronics and Information Technology (MeitY) to issue notifications to social media platforms, compelling them to block or suspend various websites, social media accounts, and channels infringing Sadhguru's exclusive rights.
• Social media platforms, including YouTube, Instagram, and X (formerly Twitter), were specifically directed to identify and remove such content promptly.
• Platforms were also mandated to furnish details of those responsible for uploading the infringing content.

The tension between Google's stance—that platforms require specific URLs or detailed reports to take down offending content and cannot act proactively without formal takedown requests —and the court's 'dynamic+' injunction highlights a critical legal and operational challenge in the digital age. While intermediaries typically benefit from "safe harbor" provisions, limiting their liability until specific notice is given, the 'dynamic+' injunction seeks to overcome the "hydra-headed" nature of online infringement by allowing for future, unnamed infringers to be covered. This effectively pushes intermediaries towards a more proactive monitoring and takedown role, even if court-monitored. This indicates a judicial effort to evolve intermediary liability frameworks to better cope with the scale and speed of AI-driven infringement, potentially leading to new guidelines or interpretations for platforms that necessitate more than just reactive measures.

In The News: Not Just Sadhguru, AI Misuse Rampant in India

Several landmark cases have significantly shaped the interpretation and enforcement of personality rights in India, particularly in the context of digital presence and emerging technologies like AI:

• D M Entertainment v. Baby Gift House (2012): The Delhi High Court granted an injunction against the unauthorized use of singer Daler Mehndi's images, establishing a precedent for recognizing personality rights in India.
• Amitabh Bachchan v. Rajat Nagi (2022): This case extended legal protection to legendary actor Amitabh Bachchan against the misuse of his personality traits. The Delhi High Court issued its first John Doe order for personality rights, which applies against the world at large, including future defendants and future mediums like NFTs and the metaverse.
• Anil Kapoor v. Simply Life India & Ors. (2023): The Delhi High Court recognized that the proliferation of technology, including artificial intelligence, facilitated unauthorized representation of a celebrity's persona, necessitating vigilant protection. The court acknowledged the right to endorsement as a "major source of livelihood for the celebrity".
• Arijit Singh v. Codible Ventures LLP (2024): The Bombay High Court ruled that the singer's personality attributes, including his name, voice, photograph, likeness, vocal style, vocal technique, vocal arrangements and interpretations, mannerisms, and signature, were protectable. This was the first Indian judgment to directly address the misuse of generative AI tools, intellectual property, and music, holding that making AI tools available to convert any voice into that of a celebrity without permission violates personality rights.
• Jaikishsan Kakubhai Saraf alias Jackie Shroff v The Peppy Store & Ors (2024): The court specifically addressed and restrained an AI chatbot from using attributes of Bollywood actor Jackie Shroff's persona without consent.
• Dr Devi Prasad Shetty & Anr v Medicine Me & Ors (2024): The Delhi High Court granted an ex parte ad interim order against deepfakes using a renowned cardiac surgeon's likeness to promote dubious drugs or false health tips.
• Ankur Warikoo v. John Doe (CS(COMM) 514/2025): The Delhi High Court issued a broad John Doe injunction restraining unidentified individuals from using the name, image, voice, or likeness of Ankur Warikoo (a prominent personal finance educator) via deepfakes for fraudulent investment schemes. It mandated social media platforms to remove content within 36 hours and disclose creators' information.

These precedents show a clear trend of courts recognizing an increasingly granular set of attributes as part of a protectable "personality," moving beyond just name and image to include voice, vocal style, mannerisms, and even signature, especially when AI can replicate these. Early cases like Daler Mehndi focused on unauthorized image use. Subsequent cases, such as Amitabh Bachchan , expanded protection to broader "personality traits" and "future mediums." The Arijit Singh case specifically included voice, vocal style, and mannerisms , and Sadhguru's case further solidified this by listing "vocal articulation style and his unique attire, looks or appearance". This progression illustrates the courts' deepening understanding that AI's capabilities necessitate a broader, more nuanced definition of what constitutes a "persona" that can be exploited, thereby expanding the scope of legal protection to encompass the full spectrum of a digital identity.

The increasing and widespread use of John Doe orders highlights the fundamental challenge of identifying anonymous online infringers and the judiciary's pragmatic and essential response to this. The "hydra-headed" nature of rogue websites and their ability to mask registration details make traditional litigation against named defendants extremely difficult. John Doe injunctions, which apply to unknown future violators, are a direct judicial adaptation to this pervasive challenge. This signifies a recognition that the anonymity facilitated by digital platforms requires a legal mechanism that can operate effectively even when the perpetrators are initially unidentifiable, making enforcement more practical and efficient in the face of rapidly evolving threats.

Evolution of Personality Rights Jurisprudence in India

The legal framework for personality rights in India is characterized by the absence of a standalone, dedicated statute. Instead, protection for these rights is currently achieved through a "patchwork" of existing legal provisions and common law doctrines. This includes the Trade Marks Act of 1999, which primarily prevents consumer confusion by ensuring that only the rightful owner can use a distinctive mark in commerce. The Copyright Act of 1957 also plays a role by safeguarding original creative works, though its protection extends only to the "expression" of an idea, not the idea itself.

A significant common law doctrine utilized is 'Passing Off,' which applies when the unlawful use of a mark or persona misleads the public into believing an association with an established entity. To succeed in a 'Passing Off' claim, a plaintiff must demonstrate misrepresentation, deceit, and damage to their brand's goodwill. Additionally, Article 21 of the Indian Constitution, which guarantees the Right to Privacy, provides a foundational, albeit incomplete, semblance of protection for personality rights, as it does not fully address the commercial aspects of identity misappropriation. The right to publicity, which grew out of the right to privacy, is recognized as an intellectual property right that protects the pecuniary interest in the commercial exploitation of an individual's identity. For legal protection, plaintiffs must generally prove their celebrity status, identifiability from the unauthorized use, and that such use is for commercial gain.

The consistent reliance on common law doctrines, constitutional provisions, and the evolution of existing intellectual property statutes demonstrates that Indian courts are actively shaping personality rights law in response to technological advancements. The research explicitly states "no specific legislation" for personality rights but details a robust series of landmark cases. This indicates that the judiciary is not merely applying static law but is engaged in a dynamic process of "judicial innovation" to interpret and expand existing legal principles to cover new forms of digital infringement, especially those involving AI. This suggests a flexible, albeit fragmented, legal landscape where case law plays a crucial role in defining rights and liabilities, often leading the way for legislative consideration.

Broader Implications and Challenges in the AI Era

The Delhi High Court's ruling in the case extends beyond the immediate parties, casting a wide net of implications for personality rights and the challenges posed by Artificial Intelligence. The enforcement of such injunctions against AI misuse faces significant hurdles, primarily due to the "hydra-headed" nature of online infringement. Rogue websites, even after being blocked or deleted, possess the remarkable ability to resurface in various forms—as alphanumeric or mirror sites—with minimal alterations. This resilience makes it exceedingly difficult to identify and locate the operators of such sites, as they frequently mask their registration and contact details. The inherent difficulty in tracing the origin of deepfakes, often created anonymously or hosted on foreign servers, further complicates legal enforcement under Indian law. Compounding this, law enforcement and cyber law authorities often lack the specialized technical expertise required to identify deepfakes, leading to investigative delays and weak enforcement actions. The rapid proliferation and potential for damage from AI-generated content necessitate immediate judicial action, frequently resulting in "ex parte ad interim injunctions," which, while providing quick relief, can be complex to enforce across diverse platforms.

This description of "hydra-headed" websites and the inherent difficulty in tracing their origins points to an ongoing technological "arms race" between infringers and rights holders/enforcement agencies. The constant resurfacing of infringing content with minor changes means that even with dynamic injunctions, enforcement is a continuous, resource-intensive battle. This highlights that legal solutions alone are insufficient; they must be complemented by sophisticated AI-driven detection tools and continuous adaptation by legal and technical frameworks to stay ahead of malicious AI use. This implies a need for sustained investment in technological countermeasures and robust international cooperation to effectively combat digital piracy and deepfake proliferation.

The Role and Responsibilities of Digital Intermediaries

A critical aspect of the ruling involves the evolving role and responsibilities of digital intermediaries. The court explicitly directed social media platforms, including YouTube, Instagram, and X, to promptly identify and remove infringing content. Furthermore, the Ministry of Electronics and Information Technology (MeitY) and the Department of Telecommunications (DoT) were mandated to assist in enforcement and ensure compliance with takedown protocols. Platforms were also directed to furnish details of those responsible for uploading the infringing content.

However, representatives from Google, acting as an intermediary, argued that platforms typically require specific URLs or detailed reports to take down offending content and cannot act proactively without formal takedown requests, aligning with current intermediary guidelines in India. While the Intermediary Guidelines and Digital Media Ethics Code, 2021, do require platforms to act on content complaints, their enforcement often remains weak.

The court's directives to social media platforms and government bodies indicate a judicial push towards a more proactive and accountable role for intermediaries, potentially moving beyond the traditional "notice and takedown" regime. While intermediaries like Google assert their reliance on specific URL reporting in line with "safe harbor" provisions, the court's 'dynamic+' injunction and directives for platforms to "identify and remove such content promptly" and "furnish details of those responsible" suggest a significant shift. This implies that the judiciary is increasingly expecting platforms to leverage their technological capabilities to actively monitor and prevent infringement, rather than merely reacting to individual complaints. This could lead to a re-evaluation of intermediary liability frameworks in India, especially concerning AI-generated content, potentially imposing more stringent, albeit court-monitored, obligations on platforms.

Balancing Innovation, Free Speech, and Individual Rights

The ruling also underscores the delicate balance that courts and policymakers must strike between fostering technological innovation, upholding freedom of speech, and safeguarding individual rights. The court emphasized the need to balance freedom of speech and expression with the right to reputation, which is recognized as an integral component of an individual's dignity.

A continuous challenge lies in ensuring that regulatory measures do not stifle legitimate AI innovation. The court acknowledged the "immense degree of freedom enjoyed by developers and innovators globally today," which, paradoxically, also renders intellectual property right holders vulnerable to "rogue websites". Furthermore, courts may face difficulties in distinguishing between authentic and AI-generated evidence, which could complicate legal proceedings.

The court's implicit warning about the "dangerous edge" of immense freedom enjoyed by developers and innovators extends beyond mere legal compliance to an ethical responsibility for AI developers and the broader tech industry. The power to "fabricate reality" carries inherent risks. The court's concern suggests that the ruling, while a legal judgment, also carries an ethical message for the AI community: the immense capabilities of generative AI necessitate a strong commitment to responsible AI development, including built-in safeguards against misuse, transparency mechanisms, and adherence to ethical guidelines. This could influence future industry best practices, calls for self-regulation, and potentially lead to the integration of ethical considerations directly into future legal mandates.