$~23
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CS(COMM) 514/2025 with I.A. 13419/2025, I.A. 13420/2025, I.A.
13421/2025, I.A. 13422/2025, I.A. 13423/2025, I.A. 13424/2025 &
I.A. 13425/2025
ANKUR WARIKOO & ANR. .....Plaintiffs
Through: Ms. Swathi Sukumar, Senior
Advocate with Mr. Rishabh Sharma,
Mr. Abhishek Shivpuri, Mr. Rajdeep,
Mr. Ritik, Mr. Rishabh and Mr.
Mayank Bhargava, Advocates.
versus
JOHN DOE & ORS. .....Defendants
Through: None.
CORAM:
HON'BLE MR. JUSTICE AMIT BANSAL
ORDER
% 26.05.2025
I.A. 13420/2025 (u/s 12A of the Commercial Courts Act, 2015)
1. As the present suit contemplates urgent interim relief, in light of the
judgment of the Supreme Court in Yamini Manohar v. T.K.D. Krithi, 2023
SCC Online SC 1382, exemption from the requirement of pre-institution
mediation is granted.
2. The application stands disposed of.
I.A. 13421/2025 (u/s 149 of the CPC)
3. Counsel appearing on behalf of the plaintiffs submits that the requisite
court fees shall be paid within two weeks.
4. The aforesaid statement of counsel for the plaintiffs is taken on
CS(COMM) 514/2025 Page 1 of 15
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record.
5. The application is disposed of.
I.A. 13422/2025 (u/O-XI Rule 1(4) of the CPC)
6. The present application has been filed on behalf of the plaintiffs
seeking leave to file additional documents under the Commercial Courts
Act, 2015.
7. The plaintiffs are permitted to file additional documents in accordance
with the provisions of the Commercial Courts Act, 2015 and the Delhi High
Court (Original Side) Rules, 2018 within thirty (30) days.
8. Accordingly, the application is disposed of.
I.A. 13423/2025 (seeking exemption from effecting advance service of the
plaint paperbook upon the defendant no.1)
9. The plaintiff seeks urgent interim relief against the defendant no.1
(John Doe) who have published and circulated fabricated/ deep fake content
and associated fraudulent schemes on social media platforms.
10. Therefore, in the peculiar facts and circumstances of this case,
exemption from effecting advance service of the plaint paperbook upon the
defendant no.1 is granted.
11. The application stands disposed of.
I.A. 13424/2025 (seeking exemption from filing Legal Proceeding
Certificates)
12. This application is filed on behalf of the plaintiffs seeking exemption
from filing the legal proceeding certificates of the registered trade marks of
the plaintiff no.2.
13. For the reasons stated in this application, the plaintiffs are exempted
from filing the legal proceeding certificates at this stage.
14. The application stands disposed of.
CS(COMM) 514/2025 Page 2 of 15
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I.A. 13425/2025 (seeking exemption from filing legible/ typed/ clear copies
of documents, etc.)
15. Allowed, subject to the plaintiffs filing legible/ typed/ clear copies of
documents within four (4) weeks.
16. The application stands disposed of.
CS(COMM) 514/2025
17. Let the plaint be registered as a suit.
18. Issue summons.
19. Summons be issued to the defendants through all permissible modes.
The summons shall state that the written statement(s) shall be filed by the
defendants within thirty (30) days from the date of the receipt of summons.
Along with the written statement(s), the defendants shall also file affidavit(s)
of admission/ denial of the documents of the plaintiff, without which the
written statement(s) shall not be taken on record.
20. Liberty is given to the plaintiffs to file replication(s), if any, within
thirty (30) days from the receipt of the written statement(s). Along with the
replication(s) filed by the plaintiffs, affidavit(s) of admission/ denial of the
documents of the defendants be filed by the plaintiffs.
21. The parties shall file all original documents in support of their
respective claims along with their respective pleadings. In case the parties
are placing reliance on a document, which is not in their power and
possession, its detail and source shall be mentioned in the list of reliance,
which shall also be filed with the pleadings.
22. If any of the parties wish to seek inspection of any documents, the
same shall be sought and given within the timelines.
23. List before the Joint Registrar on 4th August, 2025 for completion of
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service and pleadings.
24. List before the Court on 8th October, 2025.
I.A. 13419/2025 (u/O XXXIX Rules 1 and 2 of CPC, 1908)
25. The present suit has been filed seeking permanent injunction
restraining the defendants from infringement of personality and publicity
rights and passing off, along with other ancillary reliefs.
26. The plaintiff no.1 is stated to be a well-known personal finance
education influencer, entrepreneur, best-selling author and public speaker
having a significant online presence and following across various social
media platforms. He is renowned for his practical insights on
entrepreneurship, career management, personal growth, productivity and
personal finance.
27. In the year 2014, he was featured in Fortune India’s ‘40 Under 40’. In
2019, the plaintiff no.1 began his journey as a content creator, particularly in
the fields of personal finance, career management and personal growth. He
currently has over 15.1 million followers across various social media
platforms. In 2022, Forbes India recognised him for his content in the field
of business and finance, placing him among India’s top 100 Digital Stars. As
on date, he has authored four books, for one of which, he was awarded
Crossword Bestseller Award in 2024.
28. The plaintiff no.1 has regularly appeared in various interviews and
talk shows, delivered lectures and featured in several news articles. He
enjoys massive digital footprint which demonstrates his widespread public
recognition and influence. Several domestic and international brands have
partnered with the plaintiff no.1 to promote their products/ services on social
media. Therefore, it is submitted that social media users see the plaintiff
CS(COMM) 514/2025 Page 4 of 15
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no.1 in the content posted not just from his own profile but also through
other profiles/ accounts which post with his authorisation.
29. It is submitted that the plaintiff no.1 is a celebrity in his own right and
has valid and enforceable personality rights. The plaintiff no.1’s name,
image, voice, likeness, and overall persona are exclusively associated with
him and his own business activities.
30. The plaintiff no.2 (M/s Zaan WebVeda Private Limited) was founded
by the plaintiff no.1 in 2020. Under the mark ‘WebVeda by Ankur
Warikoo’, on its online platform, the plaintiff no.2 provides practical courses
for work and life. The plaintiff no.2 relies heavily on the brand value of the
plaintiff no.1. The plaintiff no.2 has also obtained registration for the mark
‘Warikoo’ in classes 35 and 41 in India, the details of which are given
below. Therefore, any unauthorized use of the mark ‘Warikoo’ amounts to
infringement thereof.
S. No. Mark Owner Class/ Validity
Registration Date
No.
1. Warikoo Plaintiff 41/ 5374189 17.03.2022
(word) No. 2
2. Warikoo Plaintiff 35/ 5374190 17.03.2022
(word) No. 2
31. The plaintiff no.2’s website prominently displays the registered mark
‘Warikoo’ to assert its commitment to provide high-quality services and
accessibility. In the year 2023-24 and 2024-25, the plaintiff no.2 had a total
revenue of Rs. 15,46,87,896/- and Rs. 13,71,01,241/- respectively. By virtue
of continuous and uninterrupted use, widespread promotion and exceptional
services, the marks ‘WebVeda by Ankur Warikoo’ and ‘Warikoo’ have
acquired formidable goodwill and reputation along with significant
CS(COMM) 514/2025 Page 5 of 15
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consumer recognition and knowledge. The members of public and trade
recognize the said marks and associate them solely with the plaintiffs.
32. The defendant no.1/ John Doe(s) are unidentifiable third-parties, who
create, publish and make available the infringing content in the form of deep
fakes featuring the plaintiff no.1 giving investment advice and asking he
viewers to join a WhatsApp group for more such tips on stocks that would
skyrocket in the upcoming days.
33. The defendant no.2 owns, manages and controls social media
platforms such as Instagram, Facebook and WhatsApp where such deep
fakes are widely circulating. The defendants no.3 and 4 are Department of
Telecommunications (DoT) and Ministry of Electronic and Information
Technology (Meity) respectively and they have been arrayed for the limited
purpose of ensuring compliance with takedown orders and intermediary
obligations under law.
34. The deep fakes are designed to trap innocent investors and
unsuspecting followers into joining suspicious WhatsApp groups, wherein
the participants are asked to make risky trades and investments by putting
money into unknown and suspicious digital applications/ accounts. Often,
after such participants put in their money, the account where the money is
deposited, is frozen and they are not permitted to withdraw the money.
35. It is the Plaintiffs’ case that the Deep Fakes started surfacing
sometime around August-September 2024.
36. As and when any unauthorised image, video or any deep fake content
comes to the attention of the plaintiffs, they initiate action by flagging it on
the BRP tool of the defendant no.2. However, many such deep fakes
continue to circulate and have not been taken down effectively and
CS(COMM) 514/2025 Page 6 of 15
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efficaciously by the defendant no.2. There have also been instances where
the same deep fake content has been published by two different accounts, in
which case after the plaintiffs would flag/ report both such deep fakes, the
defendant no.2 would take down one and leave the other without providing
any justification.
37. In the deep fakes, the plaintiff no.1 has been falsely shown to
recommend to his audience to join WhatsApp groups for stock tips.
Illustrative content in the deep fakes, along with the audio therein, is
reproduced below:
“Attention, investors your big opportunity is here, six months ago, we
recommended NTPC stock at ₹235 and today it sold to ₹420. If you had
invested ₹1,00,000, you’d now have ₹180,000 in your pocket today,
we’re about to we're reveal another skyrocketing stock in our free
WhatsApp group. One that could bring you incredible returns. Don’t
miss out. Join our free WhatsApp group now to get this exclusive stock
tip and maximise your profits.”
38. Neither the plaintiff no.1 has ever recorded any such video and made
CS(COMM) 514/2025 Page 7 of 15
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such claims/ statements nor has he ever endorsed any such WhatsApp
groups for stock/ investment tips. In the deep fakes, likeness, image and
name etc. (in different combination) of the plaintiff no.1 have been misused
by the defendant no.1 to deceive the public at large.
39. The infringing actions, if permitted to continue, would result in
immense financial and reputational loss to the plaintiff no.1 and disturb his
standing as a leading personal finance educator in the digital space. The
infringing actions would also have serious consequences for innocent and
unsuspecting investors. A table consisting of some of the illustrative
infringing links is provided below:
S.No. Page Name Web Link
1. Pro Investors https://www.instagram.com/p/DJCD5D2APfi/
Hub (Published on 29.04.2025, Status: Active)
2. Pro Investors https://www.instagram.com/p/DJIzebJg_pb/
Hub (Published on 02.05.2025, Status: Active)
3. Pro Investors https://www.instagram.com/p/DJCGLT4s-
Hub DK/ (Published on 29.04.2025, Status:
Active)
4. Ryan Yerger https://www.instagram.com/p/DJCN8lSsvBp/
Martinez (Published on 29.04.2025, Status: Active)
5. Stock Picks Daily https://www.instagram.com/p/DI8v4_psFAk/
(Published on 27.04.2025, Status: Active)
6. Ryan Yerger https://www.instagram.com/p/DI3GbHJA_fF/
Martinez (Published on 25.04.2025, Status: Active)
7. Cameron https://www.instagram.com/p/DHIguElA2c_/
Hegmann (Published on 13.03.2025, Status: Active)
8. Pro Investors https://www.instagram.com/p/DGgEz1ggUrf/
Hub (Published on 25.02.2025, Status: Active)
9. Pro Investors https://www.instagram.com/p/DGIZDgTAG
Mk/ (Published on 16.02.2025, Status:
CS(COMM) 514/2025 Page 8 of 15
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Hub Active)
10. Rsads https://www.instagram.com/p/DDeAL2sAgZ
u/?utm (Published on 12.12.2024, Status:
Active)
11. Clube De https://www.instagram.com/p/DCzdezuAk8V
Investimento / (Published on 25.11.2024, Status: Active)
40. Upon discovering the deep fakes, the plaintiff no.1 promptly reported
on the BRP portal of the defendant no.2 (for the deep fakes between 19th
February, 2025 and 28th April, 2025).
41. When reporting on BRP portal did not yield results, the plaintiff no.1
made a formal complaint to the Cyber Crime Cell on 7th December, 2024. In
the complaint, the plaintiff no.1 reported against 2 URLs on the defendant
no.2’s platform (Instagram). The 2 URLs were:
a. https://www.instagram.com/p/DCrNN1mgW9t/ (video) (published
on 22nd November, 2024, taken down only after 4th May, 2025,
gained almost 66,000 views)
b. https://www.instagram.com/p/DDeAL2sAgZu/?utm (image)
(continues to be active)
42. The plaintiff no.1 reported that these accounts were running fake AI
videos with his face and a fake voice luring people to join a WhatsApp
investing group, created to scam people. However, the complaint was closed
on 16th April, 2025 without resolution, or providing any reasons.
43. The plaintiff no.1, while complained to the Grievance Officer of the
defendant no.2 on 16th December, 2024, also gave an illustrative list of
URLs in respect of which the defendant no.2 failed to take any action. The
cited URLs were:
a. https://www.instagram.com/p/DCrNN1mgW9t/ (published on 22nd
CS(COMM) 514/2025 Page 9 of 15
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November, 2024) (active at least till 4th May, 2025; now taken
down)
b. https://www.instagram.com/p/DCya6DBMHY (now taken down)
c. https://www.instagram.com/p/DCzdezuAk8V/ (Still active)
44. Pertinently, all the aforesaid three links had the identical deep fake
video. Yet https://www.instagram.com/p/DCzdezuAk8V/ remains active till
date. When Grievance Officer failed to take down the infringing content, the
plaintiff no.1 filed an appeal with the Grievance Appellate Committee
(‘GAC’) on 25th March, 2025. He provided the same infringing URLs,
including https://www.instagram.com/p/DCzdezuAk8V/, to the Grievance
Appellate Committee that were shared with the Grievance Officer.
Strangely, vide Order dated 21st April, 2025, the Grievance Appellate
Committee accepted the defendant no.2’s representation that appeal was pre-
mature as it did not pertain to a specific decision by the Grievance Officer.
Accordingly, the plaintiff no.1 was asked to go back to the defendant no.2
with regard to the deep fakes.
45. On the same day, i.e. on 21st April, 2025, the plaintiff no.1 refiled the
complaint regarding the URL https://www.instagram.com/p/DCzdezuAk8V/
with the defendant no.2 on the link shared in the Grievance Appellate
Committee’s order. While the plaintiff no.1 received the acknowledgment
email with complaint no. 1499075847729117 from the defendant no.2, the
infringing link remains active.
46. Similarly, with respect to the links reported on 6th May, 2025,
including https://www.instagram.com/p/DJCD5D2APfi/,
https://www.instagram.com/p/DJCGLT4s-DK/and
https://www.instagram.com/p/DJCN8lSsvBp/, the plaintiff no.1 received the
CS(COMM) 514/2025 Page 10 of 15
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acknowledgment email with complaint no. 548746564955138 from the
defendant no. 2. Yet, the aforesaid links remain active and are under review.
47. As a result of the aforesaid, the plaintiffs and the innocent unwary
investors continue to suffer.
48. The possibility of harm is aggravated by the fact that the plaintiff no.1
is known for his content in the field of personal finance education which
pertains to (i) how to budget for expenses, (ii) how to plan for emergencies
and (iii) how to invest with a long-term horizon, etc. It is submitted that the
plaintiff no.1 does not provide buy-sell tips in his content. However, given
the broad common theme in the content posted by the plaintiff no.1 and in
the deep fakes, unwary investors are far more likely to falsely believe that
the plaintiff no.1 is the creator of the content in the deep fakes. Accordingly,
continued circulation and/ or publication of the false and misleading posts
featuring the plaintiff no.1 and depicting the plaintiff no.2’s marks will have
serious consequences not just for the plaintiffs but also for the public at
large.
49. It is submitted that there are many innocent investors who have
already lost their money believing that it was the plaintiff no.1 in the deep
fakes. One such message received by the plaintiff no.1 on 21st April, 2025 is
given below:
CS(COMM) 514/2025 Page 11 of 15
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50. The business operations and revenue streams of the plaintiff no.2,
which is intrinsically linked to the personal brand and reputation of the
plaintiff no.1, has suffered a direct and significant adverse impact following
the widespread circulation of the aforementioned malicious deep fake
content featuring the plaintiff no.1.
51. Based on the averments made in the plaint and submissions made on
behalf of the plaintiffs, it is evident that the defendant no.1 is circulating
deep fake contents unauthorizedly using the name/ mark, face, voice, etc. of
the plaintiff no.1.
52. In view of the above, 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
CS(COMM) 514/2025 Page 12 of 15
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and injury would be caused to the plaintiffs in the defendant no.1 are
allowed to continue publishing/ circulating the aforesaid deep fake contents.
53. None appears on behalf of the defendant no.2 despite advance service.
54. Issue Notice.
55. Notice be issued to the defendants through all permissible modes,
including e-mail.
56. Reply(ies) be filed within four (4) weeks.
57. Rejoinder(s) thereto, if any, be filed within two (2) weeks thereafter.
58. Consequently, till the next date of hearing, the following directions
are issued:
a. The defendant no.1/ John Doe(s), their associates, partners, directors,
principal officers, family members, servants, agents, or anyone acting
for and on their behalf, during the pendency of the suit, are restrained
from directly or indirectly misusing, misappropriating or exploiting
the name, likeness, image, photos, videos, voice or any other aspects
of the plaintiff no.1's persona, which are solely and exclusively
associated and identified with him, for any illegal commercial and/ or
personal gain, in any manner whatsoever including through the use of
Artificial Intelligence, Deep Fake technology or any other technology,
in any medium, format or platform;
b. The defendant no.1/ John Doe(s), their associates, partners, directors,
principal officers, family members, servants, agents, or anyone acting
for and on their behalf, during the pendency of the suit, are restrained
from misusing, misappropriating and exploiting the name, likeness,
images, photos, videos and/ or infringing any rights of the plaintiff
no.2, including that of the registered mark ‘Warikoo' and from
CS(COMM) 514/2025 Page 13 of 15
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claiming any association, connection and/ or endorsement with the
plaintiffs;
c. The defendants no.2 or any person acting for or on their behalf, during
the pendency of the suit, are directed to forthwith remove/ disable
access to the specific pages, URLs, profiles, accounts, videos, photos,
text, content, social media groups, and channels as detailed in
paragraph no.39 of this order (paragraph no.36 of the plaint)
published on any platform owned, managed or controlled by them
within 36 hours;
d. In case the plaintiffs, during the pendency of the present suit, discover
any more false, fabricated and/ or deep fake content not originating
from or associated with the plaintiffs, the plaintiffs shall be at liberty
to approach the defendant no.2 requesting them to block/ take down,
within 36 hours, any such post/ image/ video/ text/ or any other deep
fake content, which is published on its platforms or utilizing its
platforms. In case the defendant no.2 raises any doubt, the plaintiffs
shall be at liberty to approach this Court for appropriate orders.
e. The defendants no.2 is directed to disclose on affidavit before this
Court all available details including name, address, email address,
contact details, organization and associations, URL, IP address, etc.
associated with the page and deep fakes detailed in paragraph no.39 of
this order (paragraph no.36 of the plaint) and of any other page and
deep fake that may come into the plaintiff’s knowledge in future.
59. Compliance of Order XXXIX Rule 3 of the Code of Civil Procedure,
1908 be made within five (5) days.
60. List before the Joint Registrar on 4th August, 2025 for completion of
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service and pleadings.
61. List before the Court on 8th October, 2025.
AMIT BANSAL, J
MAY 26, 2025
Vivek/-
CS(COMM) 514/2025 Page 15 of 15
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