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The Delhi High Court bench of Justice Amit Bansal has passed a john doe order and granted reliefs in a suit filed by Ankur Warikoo (Plaintiff No. 1) seeking permanent injunction against misuse of personality rights, infringement of trademark, and dissemination of deepfake content impersonating Mr.Warikoo.
Mr. Warikoo, a well-known digital content creator, author, entrepreneur, and speaker with a substantial following on social media, and Plaintiff No.2, M/s Zaan WebVeda Private Limited, a company founded by Plaintiff No.1 which offers practical courses under the brand “WebVeda by Ankur Warikoo” and holds registered trademarks for the word “Warikoo” under Classes 35 and 41.
It was the case of Mr.Warikoo that the defendant no.1/ John Doe(s) are unidentifiable third-parties, who created, published and made available the infringing content in the form of deep fakes featuring Mr.Warikoo giving investment advice and asking the viewers to join a WhatsApp group for more such tips on stocks that would skyrocket in the upcoming days. These deepfakes used Mr.Warikoo’s likeness, image, and voice to create the false impression of endorsement. Defendant No.2, Meta Platforms Inc., was impleaded as the platform owner of Instagram, Facebook, and WhatsApp where the said content was hosted. Defendants No.3 and No.4, the Department of Telecommunications (DoT) and Ministry of Electronics and Information Technology (MeitY), respectively, were arrayed for the limited purpose of enforcement of takedown orders.
The plaintiffs submitted that the infringing content surfaced around August–September 2024 and continued to appear despite being reported through Meta’s Brand Rights Protection (BRP) tool. The complaint to the Cyber Crime Cell on 7th December 2024 was closed on 16th April 2025 without providing reasons. Further grievance redressal attempts were made by approaching Meta’s Grievance Officer and subsequently the Grievance Appellate Committee (GAC) under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. However, the GAC held on 21st April 2025 that the appeal was premature in the absence of a formal decision from the Grievance Officer.
It was highlighted to the court that Mr.Warikoo is known for his content in the field of personal finance education but has never indulged into buy-sell tips in his content, thus continued circulation and/ or publication of the false and misleading posts featuring him will have serious consequences not just for the plaintiffs but also for the public at large.
Thus after due consideration the court observed that “a prima facie case is made out in favour of the plaintiffs and against the defendant no.1. Balance of convenience is also in favour of the plaintiffs and against the defendant no.1. Irreparable loss, harm and injury would be caused to the plaintiffs in the defendant no.1 are allowed to continue publishing/ circulating the aforesaid deep fake contents”
Accordingly, the Court passed an ex parte ad interim injunction against Defendant No.1 and all persons acting on their behalf, restraining them from using Plaintiff No.1’s name, likeness, image, voice, or persona through any means, including Artificial Intelligence or deepfake technology.The Court also directed Defendant No.2 to disclose on affidavit all relevant information and digital identifiers linked to the infringing accounts and content. The matter was listed for further proceedings before the Joint Registrar on 4th August 2025 and before the Court on 8th October 2025.
Case Title: Ankur Warikoo v John Doe (CS(COMM) 514/2025
Advocate for Plaintiff(s): Ms. Swathi Sukumar, Senior Advocate with Mr. Rishabh Sharma, Mr. Abhishek Shivpuri, Mr. Rajdeep, Mr. Ritik, Mr. Rishabh and Mr.Mayank Bhargava, Advocates.
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