Dr Devi Prasad Shetty & Anr. v. Medicine Me & Ors.

Dr Devi Prasad Shetty is a cardiac surgeon and the founding chairman of Narayana Hrudayalaya Ltd, the hospital network that operates as Narayana Health and owns the registered "N-1" device mark and the "Narayana Health" mark. In 2024, videos appeared on Facebook and YouTube that used his name, image and voice to promote medicines he had never endorsed. The plaintiffs sued in the Delhi High Court as CS(COMM) 1053/2024, with an interim injunction application (I.A. 46360/2024), and obtained an ex parte interim order on 28 November 2024.¹

The suit belongs to the group of deepfake cases in which the harm is not only to the celebrity's reputation but to the public, because the fabricated endorsements were used to sell investments, products or medicines. The Warikoo, Sadhguru and Swami Ramdev orders involve the same pattern of fake investment tips, product endorsements and cures.²³

According to the judgment, the defendants fell into three groups.¹

• Facebook pages (Defendants 1 to 3). Defendant 1 posted a video dated 5 April 2024, styled as a news telecast, showing Dr Shetty promoting a drug said to cure Type II diabetes. Defendant 2 posted a video dated 12 April 2024 showing him as having formulated a drug for high blood pressure. Defendant 3 promoted an alternative hypertension treatment in a video that displayed the N-1 device mark.
• YouTube channels (Defendants 4 to 8). The channels posted health advice in Bengali and Hindi attributed to Dr Shetty, some using clips from his earlier interviews. Defendant 4 used the N-1 mark and Defendant 5 used "Narayana Health" as a hashtag.
• Platforms and government (Defendants 9 to 12). Meta (Facebook) and Google (YouTube) hosted the content, and the Department of Telecommunications and MeitY were impleaded for blocking directions. Defendant 13 was the usual John Doe.

The plaintiffs relied on a 2024 email from a member of the public showing that someone had acted on one of the videos, which the court treated as evidence of a public-health risk. The videos were reportedly created with AI tools and deepfake technology and attributed statements to Dr Shetty that he never made.¹

The interim order, passed by the Delhi High Court on 28 November 2024, restrained Defendants 1 to 8 and 13 from misusing Dr Shetty's persona, including through AI or deepfakes, and from infringing Narayana Hrudayalaya's registered marks. It directed Meta to take down the content of Defendants 1 to 3, and Google to take down the content and channels of Defendants 4 to 8, in each case with disclosure of identifying details. It gave the plaintiffs liberty to approach Meta and Google about further infringing content, and directed the Department of Telecommunications and MeitY to issue blocking directions to telecom and internet providers. The judgment does not state the judge who passed the order or the takedown timelines in it.¹ Defendant 5 separately undertook to remove the videos and not to upload them again.¹

Justice Kaurav decided the suit without a trial. Defendants 1 to 8 and 13 did not appear or file a written statement, and their right to do so was closed, so no defendant contested the suit. The court treated the averments and documents in the plaint as admitted under Order VIII Rule 10 CPC and the Delhi High Court (Original Side) Rules, 2018. It noted the caution in C.N. Ramappa Gowda and Nirog Pharma that a decree on default should follow only where no fact needs proof, found that there was no disputed fact, and held under Satya Infrastructure that requiring ex parte evidence would only repeat the verified plaint.¹

Personality rights. Relying on Anil Kapoor v. Simply Life India, the court held that the misuse of a well-known individual's persona is actionable. It said the Court protects personality and publicity rights "particularly against misuse through artificial intelligence and deepfake technology" (para 19), that the videos attributed to him statements he never made (para 17), and that the harm "extends to members of the public who may act upon such content" (para 20), because the false claims were medical claims attributed to a cardiac surgeon.¹

Trade marks. Use of the plaintiff 2's registered marks without licence was held to infringe under Section 29 of the Trade Marks Act, 1999.¹

Precedents on unopposed suits. The court followed Rajat Sharma & Anr v. Tamara Doc & Ors (CS(COMM) 1147/2024, order of 24 August 2026), where a suit over deepfake videos of a well-known journalist and infringement of INDIA TV marks was decreed against non-contesting defendants after interim compliance, and adopted its provision giving the plaintiffs liberty to approach Meta and Google. It also cited Global Health Ltd v. Denish P Kalariya and the decree against non-contesting defendants in the Anil Kapoor suit of 30 April 2024.¹

The court made the following orders:¹

• Para 27.1. A permanent injunction against Defendants 1 to 8 and 13 in terms of prayers (a), (b) and (c) of the plaint. The interim order of 28 November 2024 describes the restraint as covering misuse of the persona "through the use of any existing or future technology such as Artificial Intelligence, deep fake technology" (para 45(I) of that order).
• Para 27.2. The directions to Defendants 9 to 12 in the interim order are made absolute.
• Para 27.3. The plaintiffs may approach Meta and Google, with copies to their counsel, about later-discovered infringing content, filing supporting particulars on affidavit. The platforms must evaluate the request under their own policies. If they do not act, the plaintiffs may return to court.
• Para 27.4. The prayers for damages and costs (g) and (h) are dismissed as not pressed.
• Paras 28 and 29. A decree sheet is to be drawn up, and the suit and pending applications are disposed of.

The court did not decide prayer (f), a declaration that Narayana Health's marks are well known under Section 2(1)(zg) of the Trade Marks Act, because that requires analysis of the factors in Section 11(6), which had not been done in these proceedings. The plaintiffs' rights on that prayer are reserved.¹

Most of the Indian personality-rights orders against AI misuse are interim, ex parte injunctions that remain open for years. This judgment is one of a small number of final decrees so far, alongside the Jackie Shroff decree of 21 May 2026 and the Rajat Sharma decree of 24 August 2026 that it cites. It shows how the courts finish these suits when defendants stay away: by treating the plaint as admitted and granting a permanent injunction.

Three features matter for AI governance. First, the injunction is written to cover "existing or future technology", which means future generative tools are covered without the need for a new suit. Second, the court framed the harm as a public-health risk and not only a reputational one. That moves the case closer to consumer protection, and it is the same public-interest dimension that SpicyIP noted in the Warikoo fake-investment order, where the order nonetheless framed the harm as private.⁴³ Third, the platform mechanism, under which the plaintiff supplies affidavit-backed URLs and the platform judges them under its own policies, stops short of ordering Meta or Google to monitor proactively. That position contrasts with the Sadhguru proceedings, in which the court on 14 October 2025 asked YouTube to endeavour to remove identical or similar content using technology.

Critics of the wave of orders warn that unopposed decrees leave no record of the defences. A LiveLaw analysis of October 2025 argued that sweeping orders passed without hearing the defendants can chill satire, parody and criticism and urged legislation with express carve-outs.⁵ Here the defendants did not contest, and the content was fabricated health advice rather than satire.

The suit was decreed and disposed of on 5 October 2026. Prayer (f), the declaration on well-known marks, is reserved for a later proceeding.¹ As of 15 October 2026, no appeal against the decree has been verified.