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2025 Supreme(Online)(Del) 4342

IN THE HIGH COURT OF DELHI AT NEW DELHI
Amit Bansal, J
Sadhvi Deepika Bharti & Anr. – Appellant
Versus
Satlok Ashram Foundation & Ors. – Respondent
CS(OS) 511/2025



Advocates:
For the Appellants/Petitioners: Mr. Raghav Awasthi, Ms. Nabeena Ali Kadli, Mr. Fatehh Singh Majithia, Ms. Simran Brar
For the Respondents: Ms. Shruttima Ehersa, Mr. Varun Pathak, Mr. Thejesh Rajendran, Ms. Sana Banyal, Ms. Anannya Gogoi

The court establishes criteria for injunctive relief based on prima facie case and balance of convenience.

Headnote:The plaintiffs seek permanent and mandatory injunction against the defendants, restraining them from posting morphed content. The plaintiffs allege infringement and defamation by the defendants’ video manipulations intended to mislead the public. The court finds a prima facie case exists for the plaintiffs, and balance of convenience favors them. Hence, the defendants are restrained accordingly.

Table of Content
1. the case attributes defendants' actions as defamation through misleading content. (Para 14 , 15 , 16 , 17 , 18 , 19 , 20)
2. court finds plaintiffs established a prima facie case for injunctive relief. (Para 27 , 28 , 29)
3. order issued to restrain defendants from publishing misleading videos. (Para 30 , 31)

O R D E R

% 01.08.2025 I.A. 18631/2025 (exemption from filing of electronic evidence certificate

1. Allowed, subject to the plaintiffs filing the document within four (4)

weeks from today.

2. The application is disposed of.

CS(OS) 511/2025

3. Let the plaint be registered as a suit.

4. None appears on behalf of the defendants no.1 and 2 despite advance service.

CS(OS)511/2025 Page1of7

5. Issue summons.

6. Summons are accepted by the counsel appearing for the defendants no.6 and 7, who waive the issuance of formal summons.

7. Summons be issued to the defendants no.1 and 2, through all permissible modes. Affidavit of service be filed within two weeks.

8. The summons shall state that the written statement(s) shall be filed by the defendants within thirty days from the date of the receipt of summons. Along with the written statement(s), the defendants shall also file affidavit of admission/denial of the documents of the plaintiffs, without which the written statement(s) shall not be taken on record.

9. Liberty is given to the plaintiffs to file replication(s), if any, within thirty days from the receipt of the written statement(s). Along with the replication(s) filed by the plaintiffs, affidavit of admission/denial of the documents of the defendants be filed by the plaintiffs.

10. It is made clear that any unjustified denial of documents may lead to an order of costs against the concerned party.

11. If any of the parties wish to seek inspection of any documents, the same shall be sought and given within the timelines.

12. List before the Joint Registrar on 6th October, 2025.

13. List before the Court on 28th January, 2026.

I.A. 18629/2025 (under Order XXXIX Rule 1 and 2 of CPC

14. The present suit has been filed seeking permanent and mandatory injunction against the defendants no.1 and 2, restraining them from posting/hosting/publishing/circulating/uploading and/or disseminating, morphed and misleading content, including but not limited to videos, using content owned by the plaintiffs, along with other ancillary reliefs.

CS(OS)511/2025 Page2of7

15. The case set up in the plaint is that the plaintiff no.1 is an Indian Hindu scholar and is a sanyasi disciple of Shri Ashutosh Maharaj Ji, who was the founder of the plaintiff no.2 organisation. The plaintiff no.1 is a preacher at the plaintiff no.2 organisation.

16. It is averred in the plaint that the plaintiff no.1 has a large following on the YouTube Channel hosted by the plaintiff no.2 organisation. The plaintiffs have provided an exhaustive list of the official social media handles of the plaintiff no.1 in paragraph 3 of the plaint.

17. The plaintiff no.2 is a socio-spiritual, not-for-profit organization established under the mentorship of His Holiness Shri Ashutosh Maharaj Ji. An exhaustive list of the plaintiff no.2’s official social media handles is provided in paragraph 4 of the plaint.

18. The defendant no.1, Satlok Ashram Foundation, is an organisation started by one Sant Rampal Maharaj.

19. The grievance of the plaintiff in the present suit is that the defendant no.1 and/or the followers of the defendant no.1 have published morphed/

misleading and infringing videos containing the plaintiffs’ original content.

20. An illustration of the defendants infringing activities is provided in paragraphs 13 to 17 of the plaint wherein it is stated that on 28th June, 2025, a member of the plaintiff no.2 organisation came across a video posted by the defendant no.2 on the said date containing snippets from an original video of the plaintiffs of an event organized in 2018 by the plaintiff no.1 mixed with images and videos of Shri Sant Rampal Singh, founder of defendant no. 1 organization.

21. It

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