Ankur Warikoo v. John Doe (2025): personality rights, deepfakes, and an influencer's John Doe injunction

The Delhi High Court's emerging line on personality rights and synthetic media has so far been built largely around film and television celebrities. Ankur Warikoo & Anr. v. John Doe & Ors. moves the doctrine onto new ground. Here the plaintiff is not an actor but a digital content creator — a personal-finance educator with a following of over fifteen million — and the harm is not a tarnished brand endorsement but outright investor fraud, perpetrated by deepfake videos that weaponised his financial credibility against the public that trusted it. In an order dated 26 May 2025, Amit Bansal, J. found a prima facie case and granted a John Doe injunction with concrete takedown directions against Meta.

The facts in brief

The first plaintiff, Ankur Warikoo, is described in the order as "a well-known personal finance education influencer, entrepreneur, best-selling author and public speaker." He was recognised in Fortune India's "40 Under 40" list in 2014, has created content since 2019, commands a following of more than 15.1 million, was named among India's Top 100 Digital Stars by Forbes India in 2022, and is the author of four books. The second plaintiff, M/s Zaan WebVeda Private Limited — founded by Warikoo in 2020 — runs the platform "WebVeda by Ankur Warikoo" and holds the registered word mark "Warikoo" in Class 35 (Registration No. 5374190) and Class 41 (Registration No. 5374189), both registered on 17 March 2022.

The infringing conduct began to surface around August and September 2024. Unidentified persons — the John Doe defendants — created and circulated deepfake videos that falsely showed Warikoo giving stock tips and urging viewers to join WhatsApp groups. One fabricated pitch had him touting "NTPC at Rs 235 → Rs 420." Victims who joined the groups were drawn into making risky trades through unknown applications, after which their accounts were frozen. Warikoo had never recorded such videos or endorsed any such groups. The order records eleven illustrative infringing Instagram links, a failed attempt to use the platform's brand-reporting tool, a Cyber Crime Cell complaint that was closed without resolution, and a Grievance Appellate Committee appeal that Meta had dismissed as "premature."

Alongside Warikoo and his company, the suit — CS(COMM) 514/2025 — arrayed the John Doe defendants together with Meta (operating Instagram, Facebook and WhatsApp), the Department of Telecommunications, and the Ministry of Electronics and Information Technology.

The questions

The case raised, at one level, a straightforward question of protection: could a content creator who is not a film or television star invoke personality and publicity rights against those who impersonate him? Beneath that lay the harder problem the deepfakes presented. These were not unauthorised endorsements of a genuine product; they were instruments of fraud, "designed," as the order puts it, "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." The Court therefore had to weigh not only the harm to the plaintiff's persona but the harm to the public deceived in his name.

A second question concerned the registered "Warikoo" mark and the false claim of endorsement — whether the impersonation infringed the second plaintiff's trademark rights and amounted to passing off. A third concerned the intermediary: what takedown obligations lay on Meta, and could it be required to disclose what it knew of the infringers' identities so that the John Doe defendants could eventually be named.

What the Court held

Amit Bansal, J. found that the plaintiffs had made out a prima facie case, that the balance of convenience lay in their favour, and that they would suffer irreparable harm absent relief. Central to the plaintiffs’ case — which the Court accepted as prima facie established — was the contention that Warikoo's status as a digital creator did not place him outside the protection of personality rights:

On that footing the Court granted an interim injunction under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, to operate until the next hearing. The John Doe defendants were restrained from misusing, misappropriating or exploiting the name, likeness, image, photographs, videos, voice or any other aspect of the first plaintiff's persona "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." They were further restrained from infringing the second plaintiff's rights, including the registered "Warikoo" mark, and from claiming any association with or endorsement by the plaintiffs.

The order did not stop at the unknown infringers. Meta was directed to remove or disable the specific URLs identified in the order within 36 hours. The plaintiffs were given liberty to flag future deepfake content as it appeared, and Meta was required to block or take it down within 36 hours of such notice — a forward-looking, dynamic remedy rather than a one-time list. Finally, Meta was directed to disclose on affidavit all available identity details of the infringing pages and accounts, so that the John Doe placeholders might in time be replaced with named defendants. Compliance was to be effected under Order XXXIX Rule 3 within five days.

Analysis

What distinguishes this order from the film-and-television personality-rights cases is the nature of the injury. In the actor archetype, the wrong is typically commercial misappropriation: a likeness used to sell a product, or a reputation diluted by association with goods the celebrity never endorsed. The Warikoo deepfakes did something more dangerous. They exploited the specific trust that attaches to a finance educator — the very authority on which his audience relies for guidance about money — and turned it into bait. The order's framing of the conduct as "designed to trap innocent investors" treats the public harm as an aggravating dimension of the case, not merely as background to the plaintiff's private grievance.

That framing matters for how the relief is shaped. A conventional personality-rights injunction protects the celebrity. Here the dynamic takedown mechanism — liberty to flag new content, with a 36-hour response obligation on Meta — is calibrated to the reality that deepfake fraud is not a single act but a recurring one, with fresh videos surfacing faster than any static list can capture. By coupling the injunction with an ongoing intermediary duty and an identity-disclosure direction, the Court addressed the structural problem of anonymous, replicating impersonation rather than only the instances before it.

The order also illustrates how personality rights and trademark protection can reinforce one another. Because Warikoo had registered his own surname as a word mark through his company, the false endorsement was simultaneously an infringement of a registered mark and a misappropriation of persona. The two claims pull in the same direction: the registered "Warikoo" mark gives the publicity-rights claim a statutory anchor, and the personality-rights claim explains why the mark's misuse is so harmful. For creators who have formalised their personal brand in this way, the combination offers a sturdier footing than either right alone.

It bears emphasis that this is an interim order, granted on a prima facie assessment and operative until the next hearing. The Court has not finally adjudicated the rights at stake; it has held the line while the suit proceeds and while Meta's disclosures may bring the John Doe defendants into the open. The order's significance lies less in any final pronouncement than in the speed and shape of the protection it extends.

Why it matters

Warikoo v. John Doe sits within the Delhi High Court's developing AI-and-deepfake personality-rights line — alongside the orders protecting Anil Kapoor (2023), Jackie Shroff (2024) and Aishwarya Rai Bachchan (2025), and the relief sought by Bhuvan Bam. What makes it notable is that it is among the first Delhi High Court orders to extend that protection to a digital content creator rather than a film or television celebrity, and to address head-on the use of deepfakes for financial scams. By acting, at the interim stage, on the premise that a finance influencer is "a celebrity in his own right," the Court signalled that publicity rights are not the preserve of the traditional entertainment industry but attach to any persona that has acquired distinct commercial value.

For practitioners advising creators and platforms alike, the order is instructive on remedy as much as on right. It shows a court willing to pair a John Doe injunction with concrete intermediary obligations — a 36-hour takedown window, a dynamic mechanism for future content, and identity disclosure on affidavit — to make the protection operative against anonymous and self-replicating infringement. As synthetic media lowers the cost of impersonation, the Warikoo order offers an early template for how Indian courts may respond when a trusted public voice is cloned to defraud the very audience that trusts it.

Related on Valkya

• Delhi HC: Varun Dhawan personality rights
• Delhi HC: personality rights & deepfakes doctrine
• X Corp v. Union of India (Sahyog portal, s.79)

Sources

• SCC Online Blog, "Delhi High Court | Ankur Warikoo gets John Doe injunction against deepfake/AI misuse" — https://www.scconline.com/blog/post/2025/05/29/delhi-high-court-ankur-warikoo-john-doe-injunction-deepfake-ai-misuse-legal-news/
• LiveLaw, "Delhi High Court Restrains Circulation Of Deepfake Videos Of Ankur Warikoo" — https://www.livelaw.in/high-court/delhi-high-court/delhi-high-court-ankur-warikoo-deepfake-videos-restrained-293539
• Bar & Bench, "Delhi High Court directs takedown of deepfake videos of YouTuber Ankur Warikoo" — https://www.barandbench.com/news/delhi-high-court-directs-takedown-of-deepfake-videos-of-youtuber-ankur-warikoo