Delhi High Court Protects Personality Rights of Spiritual Leader Aniruddha Bapu; Examines Maintainability of Personality Rights Suits
Delhi High Court Protects Personality Rights of Spiritual Leader Aniruddha Bapu; Examines Maintainability of Personality Rights Suits
The Delhi High Court recently heard a unique personality rights suit filed by Mumbai-based social, cultural, and spiritual leader Dr. Aniruddha Dhairyadhar Joshi, popularly known as Aniruddha Bapu, seeking to restrain his followers from portraying him as a deity in devotional and AI-generated content. Justice Tushar Rao Gedela described the suit as “very surprising,” noting:
“Faith moves mountains… This is something very surprising. You have come up with a very surprising suit.”
Background
Dr. Joshi filed the suit to remove deepfake videos and AI-generated images depicting him alongside Hindu gods or as divine figures such as Narad Muni or Dattatreya. His counsel emphasised:
“I am not a god… I follow a path of the Divine. I am not the Divine.”
The grievance is rooted in protecting personal autonomy and preventing misrepresentation, rather than conventional reputational harm.
Procedural History
The matter was filed as a personality rights suit against intermediaries, including social media platforms. The Court examined whether devotional content could infringe personality rights and whether intermediaries could be directed to take down content.
The plaintiff was represented by Senior Advocate Rajshekhar Rao, instructed by Argus Partners, with R. Sudhinder (Senior Partner), Ekta Bhasin (Counsel), and Anand Amit (Associate) supporting the team. The matter is listed before the Joint Registrar on April 29, 2026, and before the Court on August 25, 2026.
Key Issues
- Whether devotional portrayals of a public figure as a deity violate personality rights.
- Whether AI-generated and deepfake content falsely attributing statements warrants removal.
- Whether intermediaries can be directed to act without precise URL identification.
- Whether Delhi is the appropriate forum when the plaintiff and most followers are in Maharashtra.
Parties’ Contentions
- Plaintiff: Unauthorized portrayals, even devotional, infringe personal autonomy and personality rights; consent is required.
- Meta (Facebook): Majority of posts are praise; devotional content without egregious misuse may not constitute infringement.
- Google: Some cited YouTube links already unavailable; compliance should follow IT Rules once URLs are identified.
- Jurisdiction: Plaintiff argued global cause of action, citing Section 20(c) of the CPC and Delhi-based user engagement.
Court Analysis
Justice Gedela acknowledged the balance between faith-based expression and individual autonomy:
“A person doesn’t want his rights to be exploited in any manner. Somebody may be doing it out of devotion. But then he doesn’t want it.”
The Court noted the potential future misuse of AI content:
“Today, it may be all positive. Tomorrow, you don’t know. AI can be done like this. It can be used in a different way also.”
It also clarified that relational labels used in posts, like “Dad,” do not alter the infringement analysis.
Interim Relief
The Court granted interim relief directing intermediaries to:
- Remove infringing posts.
- Furnish BSI details of infringers.
- Act only upon precise URLs with corresponding screenshots for compliance.
The bench highlighted that practicality and forum convenience are relevant, particularly as the dispute is primarily centered in Maharashtra. Final orders on jurisdiction and scope of relief are pending.
Representation: Dr. Aniruddha Bapu was represented by Senior Advocate Rajshekhar Rao, with R. Sudhinder (Senior Partner), Ekta Bhasin (Counsel), and Anand Amit (Associate) of Argus Partners.
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