This is an informal case summary prepared for the purposes of facilitating exchange during the 2025 WIPO IP Judges Forum.
Session 6: Personality Rights
Delhi High Court, India [2025]: Sadhguru Jagadish and Another v Igor Isakov and Others, SCC OnLine Del 3804
Date of judgment: May 30, 2025
Issuing authority: Delhi High Court
Level of the issuing authority: First Instance
Type of procedure: Judicial (Commercial)
Subject matter: Others
Plaintiff: Sadhguru Jagadish Vasudev and Another
Defendant: Igor Isakov and Others
Keywords: artificial intelligence, personality rights, publicity rights, deepfake, dynamic injunction
Basic facts: Sadhguru Jagadish Vasudev (Plaintiff No. 1), a renowned spiritual leader, yogi, and public figure with global recognition for his teachings on yoga, spirituality, and humanitarian initiatives (including awards like the Padma Vibhushan), along with the Isha Foundation, a non-profit trust established by Plaintiff No. 1 (Plaintiff No. 2), filed a suit seeking permanent injunction against infringement of his personality and publicity rights. The defendants were rogue websites and unknown entities using AI tools and modern technology to create deepfakes, morph his voice, image, likeness, and speeches for commercial scams, including fake financial platforms (e.g., Trendtastic Prism), product promotions (e.g., hair products, books), and unauthorised YouTube channels disseminating altered spiritual content to gain views, subscribers, and profits. Plaintiffs became aware of these activities in December 2024 and notified platforms like YouTube, but infringements persisted.
Held: The Delhi High Court granted an ex parte ad interim ‘dynamic+’ injunction restraining Defendants Nos. 1-41 and 48 from exploiting Plaintiff No. 1’s personality rights (name, image, voice, likeness, etc.) without authorization, including via AI or any technology for commercial gain.
Relevant holdings in relation to Personality Rights: The Court held that given the plaintiff No. 1's unique position as a trusted source for spiritual guidance worldwide, any misrepresentation of his endorsement risked irreparable damage not only to his personal reputation but also to public trust at large. Such acts of misrepresentation disproportionately harm plaintiff No. 1, as they strike at the very foundation of his professional standing, which is inextricably linked to public trust. For these reasons, the gravity of the case extended beyond mere economic considerations and implicated larger issues of public welfare, consumer protection, and the integrity of public discourse.
The Court found the plaintiffs had proven a prima facie case of personality rights infringement and the balance of convenience also tilted towards the plaintiffs. If an ex parte ad interim injunction in favour of the plaintiff were not granted, the plaintiff would likely suffer irreparable loss and injury. The Court observed that if the defendants’ activities were allowed to continue they would soon spread like a pandemic online and via social media, with wide uncontrollable repercussions. It would be implausible to ask the plaintiffs, to run/chase after each one of the ‘unknown’ defendants’ ‘rogue websites’ and/or to respond to the world at large qua the ‘originality’ of the plaintiffs. Thus, the Court decided to pass a dynamic+ injunction, observing that rights of a plaintiff, cannot be rendered otiose in this world of rapidly developing technology. Enforcement of intellectual property rights online and in the real world ought to be visible and effective.
Relevant legislation: Code of Civil Procedure, 1908; Trade Marks Act, 1999