Sadhguru Jagadish Vasudev & Anr. v. Igor Isakov & Ors.

Sadhguru Jagadish Vasudev is a spiritual leader, yogi and public figure and the founder of the Isha Foundation, a non-profit trust established by trust deed on 7 January 1992. In 2025 he and the Foundation sued in the Delhi High Court, saying that from December 2024 their attention had been drawn to websites, social-media accounts and YouTube channels that used his identity, often through AI, to deceive the public.¹

The plaintiffs alleged that the defendants used AI and other technology to morph and doctor his voice, speeches and interviews and so produce deepfakes and misleading audio-visual content. The conduct fell into four groups, as the order records it:¹

• Investment scam (Defendants 1 and 2). Websites allegedly carried fake news reports of his detention and a fake interview titled the "SKAVLAN SHOW" in which he appeared to promote earnings from a platform called "Trendtastic Prism". The domains redirected visitors to sub-domains while the main domain stayed inactive. An X account promoted an NFT, "3rdEyeNFT", through an AI-generated avatar of him.
• Product endorsement (Defendants 3 and 4). An Instagram account used his image and voice to promote a hair-health product, and a seller of pregnancy-related books used his name and images to imply endorsement.
• YouTube channels (Defendants 5-41). Channels allegedly presented AI-generated speeches as genuine teachings, many of them dedicated solely to him.
• Concealment. The plaintiffs said the defendants masked registration details and used redirects and mirror sites, making them hard to find.

Before suing, the plaintiffs' representatives sent takedown requests to YouTube on 10 and 13 May 2025 under the IT Rules, 2021, the IT Act, the Indian Penal Code and YouTube's own policies. They also said that YouTube had removed some content after a Grievance Appellate Committee order of 12 March 2025.¹

The suit, CS(COMM) 578/2025, names 48 defendants. Defendants 1 to 41 are the "rogue websites" or primary defendants, and the cause title is "Igor Isakov & Ors". Defendant 42 is a domain-related intermediary, Defendant 43 is X (formerly Twitter), Defendant 44 is the Meta platform that hosts the account of Defendant 3, Defendant 45 is YouTube, and Defendants 46 and 47 are the Department of Telecommunications and the Ministry of Electronics and Information Technology, impleaded as proforma defendants so that blocking directions can be issued. Defendant 48 is "Ashok Kumar(s)/John Doe(s)".¹

The plaintiffs appeared through Srikrishna Rajagopal and a team of advocates. YouTube was represented by Mamta R. Jha and colleagues, and the DoT and MeitY by Sandeep Kumar Mahapatra and Tribhuvan.¹

Justice Saurabh Banerjee passed an ex parte, ad-interim order on 30 May 2025. He first exempted the plaintiffs from pre-institution mediation under the Commercial Courts Act, relying on Yamini Manohar v. T.K.D. Krithi and a Division Bench decision in Chandra Kishore Chaurasia v. R.A. Perfumery Works, because they sought an ex parte injunction.¹

On the merits, the court said Sadhguru is a "known person/ personality" whose voice, name, likeness, articulation style and attire are uniquely associated with him. It found a prima facie case and said that without interim relief he would suffer irreparable loss and injury. It stated that there was "every likelihood" that the "rogue website" defendants would continue to disseminate such content without authorisation.¹

The court then relied on Applause Entertainment v. Meta Platforms (Bombay High Court) and Universal City Studios v. Dotmovies.baby (Delhi High Court, 2023) to justify what it called a "dynamic+" injunction. It noted that blocked sites often reappear as "hydra-headed" mirror or alphanumeric sites with minor changes, so relief that covers only known URLs would be ineffective.¹ The directions in para 46 were as follows:¹

1. Injunction. Defendants 1-41 and 48, and those acting through them, are restrained from using Sadhguru's name, image, likeness, voice and other persona attributes for commercial or personal gain without his express written authorisation. The order says this includes AI tools in any medium or platform.
2. Domains (Defendant 42). Suspend, lock or disable expressindia9510.xyz and newstoday0124.xyz, and any later-identified domains notified by affidavit, and disclose registrant and billing details.
3. X (Defendant 43). Take down the specified post and any later-identified posts or accounts, and disclose basic subscriber information.
4. Meta platform (Defendant 44). Suspend or block Defendant 3's account and later-identified accounts, and disclose basic subscriber information.
5. YouTube (Defendant 45). Suspend or take down the accounts and channels of Defendants 5-41 that carry exclusively infringing content, and any later-identified ones, and disclose basic subscriber information.
6. DoT and MeitY (Defendants 46 and 47). Issue notifications directing service providers and social-media platforms to block the primary defendants' sites, accounts and channels, including those notified later.
7. Future deepfakes. If the plaintiffs find further deepfake content, they may ask YouTube to block or remove it within 36 hours. If YouTube doubts the request, the plaintiffs may return to court.

The order also allowed the plaintiffs to file video evidence on an encrypted pen drive with a hash value, and issued summons returnable before the Joint Registrar on 3 September 2025, with the first hearing before the court on 14 October 2025.¹

On 14 October 2025 Justice Manmeet Pritam Singh Arora recorded compliance by several intermediaries. X said it had taken down the link in para 46(iii) and argued that the post was satire; the plaintiffs, satisfied with the removal, did not insist on subscriber details and the court exempted X from sharing them. Meta said it had complied with para 46(iv), and the DoT and MeitY said they had complied with para 46(vi) and undertook to file a compliance affidavit. YouTube said it had taken down the URLs under para 46(v) and provided subscriber information, and that it had actioned further URLs the plaintiffs requested.²

The plaintiffs also pointed to a YouTube link as a "gross misrepresentation" under Google Ads policy, relied on Rule 4(4) of the IT Rules, 2021, and asked YouTube to adopt technology to identify identical content so that they would not have to keep flagging the same material. YouTube agreed to cooperate. The court directed the parties to meet, with the plaintiffs identifying content that falls within the Google Ads policy and YouTube endeavouring to remove identical or similar content through its technology. If YouTube has technological limits, it must file an affidavit saying so.²

The suit was later moved to Justice Jyoti Singh. On 25 February 2026 it was listed for 11 May 2026, and on that date the court recorded that the interim order would continue and listed the matter on 17 September 2026. A further application (I.A. 9286/2026) appears in the cause title, and counsel appeared for Defendant 51, which means that the array of defendants has grown beyond the original 48.⁷³⁴

The order is a short ex parte ruling, and it rests more on recognisability and the likelihood of continued misuse than on a developed doctrine. The court did not explain whether the right it was protecting arises from privacy and dignity or from the commercial value of identity. It did not examine consumer confusion, intent to deceive or proven reputational harm before restraining the defendants.¹⁵

SpicyIP published a critique on 15 June 2025 of this order and the Delhi High Court's order in the Ankur Warikoo case. The author argues that courts presumed infringement from recognisability alone, that the Sadhguru order did not address NFTs and tokenisation even though the complaint raised them, and that courts are applying pre-digital frameworks to deepfakes and synthetic media. On the "dynamic+" injunction, she writes that it let the plaintiff notify new infringing content and compelled platforms to act within 36 hours, which is swift but lacks nuance. She also says the 36-hour period came out of an ex parte process in which satire, fair use and lack of confusion were never put on the record, creating a risk of over-removal of lawful expression. She suggests a confusion test as in trade mark law and an academic amicus before blanket ex parte orders.⁵ A LiveLaw analysis of October 2025 names Sadhguru among the celebrities seeking such relief and makes a similar point more broadly, warning that sweeping John Doe orders can restrain satire and criticism and urging legislation with express carve-outs for protected speech.⁶

The order's own justification is the harm shown on the record, in which the deepfakes were used to sell investments and products to the public, and its finding that blocked sites reappear in altered form. The investment-scam allegations also give the case a fraud dimension that purely merchandise cases lack.¹

This order is one of the clearest Indian examples of a court addressing generative-AI deepfakes through personality rights. Four points are worth noting.

• Synthetic speech and avatars are within the injunction. The restraint covers AI tools in any medium, so it reaches AI-generated "teachings", cloned voice and avatars, not just copied photographs.
• Relief is forward-looking. The "dynamic+" formula and the 36-hour notice-and-removal mechanism shift the burden of finding new copies onto a notice procedure, rather than a fresh suit for each domain or channel.
• Platforms are asked to use technology. The 14 October 2025 order records that YouTube should endeavour to use technology to find identical or similar content, which edges towards the proactive-monitoring expectations discussed under the IT Rules, 2021.²
• The state is part of enforcement. MeitY and the DoT are asked to notify blocking, and the plaintiffs had earlier used the Grievance Appellate Committee route to obtain removals.¹

The order sits alongside the Bachchan, Anil Kapoor, Jackie Shroff and Arijit Singh orders described in the overview entry on AI personality-rights orders.

The suit is pending and the ex parte interim order continues. On 17 September 2026 Justice Jyoti Singh recorded that no one appeared for the defendants, directed that the interim order continue until the next date of hearing, and listed the matter for 10 February 2027. The order does not declare the defendants ex parte or grant a decree, and it records no default finding.⁴

As of 15 October 2026, no final judgment, decree or settlement has been verified for this entry.