Akshay Tanna v. John Doe & Ors. (Delhi High Court orders against a deepfake investment-fraud network)

Akshay Tanna is a private-equity professional described in the court's orders as the head of private equity advisory at KKR India Advisors Private Limited. Unknown persons used his name and photographs on social media and messaging platforms to impersonate him and run an investment scam, soliciting money and asking people to deposit funds in certain bank accounts. The plaint listed about 11 Facebook profiles and 12 messaging groups, including WhatsApp groups. It alleged that a deepfake video, created with AI, was used to lend a false likeness to the plaintiff. Mr Tanna said he had repeatedly disclaimed the profiles and groups, and that neither he nor KKR India gives stock tips on social media or messaging apps.¹ The December 2024 judgment adds that the defendants also falsely associated him with KKR and its trademarks and ran WhatsApp groups, Telegram profiles, Facebook pages and an Instagram account offering investment or stock tips, and that notices sent to WhatsApp, Meta and the defendants in January 2024 produced limited results.²

MediaNama lists the case among the Delhi High Court's deepfake matters, as one in which scammers used a deepfake of a private-equity executive to run an investment fraud.³ A deepfake of a known financial figure lends a scam credibility, while the people running it are anonymous and operate across platforms, phone numbers and bank accounts that must be traced separately.

The suit, CS(COMM) 92/2024, was filed in the original side of the Delhi High Court with an application for interim relief under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure. Justice Sanjeev Narula heard it ex parte on 5 February 2024. The defendants were "John Doe", the unknown operators of the profiles and groups; an individual calling himself Anurag Thakur who claimed to be the plaintiff's assistant; Telegram FZ-LLC; and Meta Platforms Inc. was directed to act.¹

The court found, prima facie, that the unknown operators were not connected with the plaintiff or KKR and had no authority to give investment advice in their names. It held that the plaintiff had made out a prima facie case, that he would suffer irreparable loss without interim relief and that the balance of convenience favoured him, and it cited the public interest, given the risk to investors.¹ The order:

• restrained defendants 1 and 2, and anyone acting for them, from using the plaintiff's name, likeness, image, photographs or other personality attributes, or claiming association with him;
• directed Telegram and Meta to remove or block the listed accounts, profiles and groups and any similar ones they host, with the plaintiff free to send them URLs of new similar content, on which they must act "in accordance with law"; and
• directed MeitY and the Department of Telecommunications to issue directions to telecom and internet service providers and domain-name registrars to block the phone numbers, websites and domain names identified as misusing the plaintiff's name.¹

The court exempted the plaintiff from advance service and pre-institution mediation in view of the urgency and directed that electronic evidence be placed on record in a non-editable format.¹

Telegram filed a compliance affidavit saying it had blocked the listed accounts. Defendant 2 was served through WhatsApp and Telegram, and an affidavit of service was filed on 14 October 2024. On 26 November 2024 the Joint Registrar closed defendant 2's right to file a written statement because he never appeared, and he was proceeded against ex parte.²

On 5 December 2024 Justice Amit Bansal delivered an oral judgment decreeing the suit under Order VIII Rule 10 CPC, which allows a court to pronounce judgment when a defendant fails to file a written statement. Because none was filed, the plaintiff's averments were treated as admitted. The documents were also deemed admitted under the Delhi High Court (Original Side) Rules, 2018 because no admission or denial affidavit was filed. The court held that defendant 2's failure to contest, despite the interim injunction, showed he had no defence on the merits, and that unauthorised impersonation, fraud and exploitation of the plaintiff's identity had been shown. It found the defendants were trying to defraud the public by offering investment advice tied to the plaintiff and KKR, causing confusion among consumers.²

The relief granted was a permanent injunction against defendants 1 and 2, and a decree on the takedown prayer in line with the February 2024 directions to Telegram and Meta. One prayer had already been granted in February and several others were not pressed. The judgment contains no directions to banks.²

The court did not need to decide new law. It relied on settled doctrines of impersonation, goodwill and personality rights, plus the power to grant dynamic, John Doe relief against unidentified wrongdoers. The AI element, the deepfake video, appears as one part of the fraud rather than a separate cause of action; the orders do not rest on any deepfake-specific statute.

For AI governance, the case shows four things.

Existing law carries the load. The remedies used were tort-style protection of identity and the court's power over intermediaries, not any AI statute. The same pattern is visible in the personality-rights orders covered elsewhere on this wiki.

Government agencies as enforcers. By asking MeitY and the DoT to direct blocking of numbers and domains, the court used executive machinery to give an injunction against unknown defendants any practical effect.

Platform duties are case-specific. Telegram and Meta were told to remove listed accounts and similar ones notified by the plaintiff, "in accordance with law". Later remarks by the Delhi High Court in a different case point to the burden of this model. In November 2025, in Rajat Sharma's personality-rights suit, Bar & Bench reported the court as saying that intermediaries should ideally act when a person reports their deepfake, and that repeated takedown cases were turning the court into a "grievance redressal forum".⁴

Limits. The decree binds a Doe defendant, an impersonator who did not appear, and two platforms. It does not recover victims' money, reach operators abroad, or create a general duty on platforms to detect deepfake scams. A LiveLaw article of August 2026, "Regulation By Injunction", argues that courts are shaping India's AI policy through orders of this kind and notes that many are interim or ex parte, which limits their precedential value.⁵ The 2026 amendment to the IT Rules, which according to LiveLaw shortens takedown timelines for authorised notices to 3 hours and requires technical markers on AI-generated content, is the regulatory response to the same problem.⁶

The suit was decreed on 5 December 2024 and no appeal or later proceedings in CS(COMM) 92/2024 were located. As of 15 October 2026 the permanent injunction stands against defendants 1 and 2, and the platform takedown directions were made absolute in the decree. This entry does not state whether the identified accounts were removed beyond Telegram's reported compliance affidavit, or whether any person was prosecuted.²