Delhi High Court - Orders
Rajat Sharma & Anr vs Tamara Doc & Ors on 7 November, 2025
Author: Manmeet Pritam Singh Arora
Bench: Manmeet Pritam Singh Arora
$~39
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CS(COMM) 1147/2024
RAJAT SHARMA & ANR. .....Plaintiffs
Through: Mr. Saikrishna Rajagopal, Ms. Disha
Sharma, Ms. Snehima Jauhari, Ms.
Mythili Girish & Ms. Deepika
Pokharia, Advocates.
versus
TAMARA DOC & ORS. .....Defendants
Through: Mr. Aditya Gupta & Ms. Vani
Kaushik, Advocates for D-17.
CORAM:
HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA
ORDER
% 07.11.2025 I.A. 27513/2025 (under Order I Rule 10 CPC)
1. This is an application under Order I Rule 10 of the Code of Civil Procedure, 1908 ['CPC'], filed by the plaintiff seeking impleadment of proposed defendant nos. 13, 14, 15, 16 & 17.
2. This application pleads that defendant no. 13 to 16 are YouTube channels which are circulating deep fake videos by unauthorisedly using the personality of plaintiff no. 1 and spreading misinformation about political news.
3. Defendant no. 17/Google LLC, the parent company of the social media platform-YouTube, is the entity hosting the proposed defendants [defendant nos. 13-16] and the impugned content uploaded on the YouTube Channels of the proposed defendants.
CS(COMM) 1147/2024 Page 1 of 6This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/11/2025 at 21:47:29
4. The plaintiff has also separately filed another application i.e., I.A. 27483/2025 for seeking interim injunction against defendant nos. 13 to 16 with the directions of take down of their respective YouTube channels, where they have uploaded the impugned content.
5. Issue notice.
6. Learned counsel for proposed defendant no. 17 accepts notice.
7. For the reasons stated in the application and averments made in I.A. 27483/2025, this Court is satisfied that defendant nos. 13 to 16 are necessary parties and the defendant no. 17 is a proper party.
8. In view of the aforesaid, this application stands allowed and accordingly, the proposed defendant nos. 13 to 17 are hereby impleaded to the array of parties of the present suit.
9. The amended memo of parties filed along with this application is taken on record.
10. With the aforesaid, this application stands disposed of. I.A. 27514/2025 (seeking leave to file videos in a pen drive)
11. This is an application under Section 151 of the CPC, filed by the plaintiffs to file videos in a pen drive.
12. The plaintiff is directed to file the pen-drive in accordance with the Rule 24 of Chapter XI of the Delhi High Court (Original Side) Rules, 2018.
13. Registry may receive electronic record on pen-drive so long as it is encrypted with a hash value or in any other non-editable format. The video recording contained in the pen-drive be placed in the electronic record of the present suit in a format which is non-editable, so that the same can be viewed by the court during hearing.
14. With the aforesaid directions, this application stands disposed of.
CS(COMM) 1147/2024 Page 2 of 6This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/11/2025 at 21:47:29 I.A. 27483/2025 (under Order XXXIX Rule 1 & 2 CPC)
15. This is an application under Order XXXIX Rules 1 & 2 of CPC read with section 151 of CPC, filed by the plaintiffs seeking directions similar to the directions already issued in interim order dated 18.12.2024.
16. Learned counsel for the plaintiffs state that defendant nos. 13 to 16 are distinct YouTube channels, which are hosting, streaming and communicating to the public fake content that fraudulently use plaintiff no. 1's persona to broadcast fraudulent political narratives and fabricated state strategies disproportionately harming plaintiff no. 1's professional standing, which is inextricably linked to public trust and credibility. 16.1. He states that in addition, these YouTube Channels have unauthorisedly lifted copyright footage from plaintiff no. 2's flagship shows and have created doctored videos bearing distorted, modified, and modulated images/voice and other personality traits of plaintiff no. 1 to create a false impression that the content originates from or is endorsed by the plaintiffs or that the defendants' channels are associated with the plaintiffs.
16.2. He also refers to the specific instances set out at paragraph nos. 9, 11 and 12 of this application vis-a-vis each of these channels. 16.3. He also points out that, in fact, defendant no. 16 uses the persona of plaintiff no. 1 by falsely attributing to him purported commentary, analysis and opinion on the fluctuating gold and silver and commodity prices and other unrelated subject matter. Thereby, alluring unwary consumers into believing that the content is authored, endorsed or hosted by the plaintiffs and leading them to purchase products that have been tagged on these channels with the impugned content.
CS(COMM) 1147/2024 Page 3 of 6This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/11/2025 at 21:47:29
17. Issue notice.
18. Learned counsel for defendant no. 17 accepts notice. 18.1. He states that plaintiff had approached defendant no. 17 on 30.10.2025 and acting upon the said complaint, after review the accounts of the YouTube channels operated by defendant nos. 13 and 15 already stand terminated.
18.2. He states that though the complaint vis-a-vis defendant no. 14 and 16 is still under review; however, defendant no. 17 will abide by any directions issued by the Court.
19. This Court has heard the learned counsels and perused the averments made in the application.
20. The averments with respect to defendant no. 13 are set out more specifically at paragraph nos. 9 and 10 of the captioned application. It is asserted that similarly Defendant nos. 14 and 16 have misused the persona and likeness of the plaintiff no. 1 on their respective YouTube channels. Defendant no. 14's actions are specified at paragraph 11, 14, 15 and 16 and defendant no. 16's actions are specified at paragraph nos. 12, 13, 14, 15 & 16.
21. The abovementioned averments made in the captioned application categorically assert that the videos/contents uploaded on these channels are fake, doctored or AI generated impersonating plaintiff no. 1 and spreading misinformation.
22. It is stated in the application that defendant nos. 14 and 16 are rogue channels in as much as these channels are primarily posting deep fake fabricated and unauthorised videos impersonating plaintiff no. 1 and there are also two [2] other videos, which similarly contains fake content CS(COMM) 1147/2024 Page 4 of 6 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/11/2025 at 21:47:29 involving other prominent journalist and public figures in the Indian News Broadcasting Industries.
23. Having perused these averments, documents filed therewith and noting that plaintiff no. 1 has stated on oath that these are doctored videos, this Court is satisfied that the plaintiffs have made out a case for issuance of directions of take-down as prayed for against the proposed defendants. Defendant no. 17 is directed to take down YouTube channels of defendant nos. 14 and 16 within 36 hours of this order being uploaded.
24. Defendant no. 17 is also directed to disclose all available BSI, IP logs, access details, contact details and monetisation data associated with defendants channels to the plaintiff within one (1) week.
25. In addition, learned counsel for the plaintiffs states that to obviate the necessity of the plaintiffs approaching this Court frequently, defendant no. 17 may be directed to act in accordance with Rule 4(4) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ['IT Rules, 2021'] with respect to preventing uploading of identical content.
26. He states that plaintiff is willing to undertake a collaborative effort with defendant no. 17 to assist in implementing the Rule 4(4) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
27. In view the aforesaid submissions and applicable Rule, the plaintiffs and defendant no. 17 are directed to have a mutual meeting wherein the plaintiffs can bring to the defendant no. 17's attention the deep fake content which has been identified by it and has been injuncted by the order passed today and thereafter defendant no. 17 is directed to make an endeavour to CS(COMM) 1147/2024 Page 5 of 6 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/11/2025 at 21:47:29 ensure that the identical content is removed from its computer resource so as to obviate the plaintiffs of making an endeavour to keep looking out for such deep fake content on the YouTube channels uploaded on the social media platform of defendant no. 17.
28. This Court is of the opinion that, this is not only necessary to protect the plaintiffs' common law rights and the statutory rights but this will also help in stopping the spreading of misinformation to the unwary people/users consuming such content.
29. Learned counsel for defendant no. 17 states that it seeks liberty to file an affidavit if there are any technological limitations in implementing the directions issued at paragraph 27. Liberty prayed for is granted.
30. In addition, it is directed that plaintiff will be at liberty to approach defendant no. 17 with respect to any other false/fake videos/contents which are not associated with it, to bring them to the attention of defendant no. 17 with copy to the counsel appearing in this matter, who will take them down after reviewing the request. In case defendant no. 17 has any reservations it will communicate the same to the plaintiff so that it can avail its remedies.
31. List on 22.01.2026.
MANMEET PRITAM SINGH ARORA, J NOVEMBER 7, 2025/ng/IB CS(COMM) 1147/2024 Page 6 of 6 This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/11/2025 at 21:47:29