Introduction:
The growing misuse of artificial intelligence and deepfake technology has increasingly become a matter of legal concern in India, particularly when such tools are allegedly used to spread defamatory, fabricated, and manipulated content targeting individuals and institutions. In a significant development addressing this emerging challenge, the Karnataka High Court, through a vacation bench presided over by Justice S.R. Krishna Kumar, directed the State Government and police authorities to immediately remove AI-generated, morphed, manipulated, and fabricated content relating to D. Veerendra Heggade and his family members from all social media platforms, URLs, press and media outlets.
The order was passed on May 14 in Sri Sheenappa & Ors. vs. State of Karnataka & Ors., Writ Petition No. 13836 of 2026. The petition was filed by representatives associated with the Sri Kshetra Dharmasthala Rural Development Project (R) and B.C. Trust, seeking intervention against the circulation of allegedly defamatory and fabricated digital material concerning the Dharmasthala Dharmadhikari and his family.
The controversy has its roots in a sensational allegation made by a sanitation worker, who claimed that he had been instructed to bury bodies of women and children in the temple town of Dharmasthala between 1995 and 2014. The allegations eventually led to registration of a First Information Report and later prompted the constitution of a Special Investigation Team (SIT) in July 2025 to probe the alleged mass burial sites. As public interest and media attention surrounding the issue intensified, several videos, social media posts, digitally altered photographs, and AI-generated visual content allegedly targeting Veerendra Heggade and his family began circulating online.
According to the petitioners, the dissemination of such content caused severe reputational harm not only to Heggade and his family members but also to the institutions associated with Sri Kshetra Dharmasthala and the religious establishment itself. The petitioners alleged that despite earlier judicial directions in Writ Petition No. 19382 of 2023 and subsequent representations made before police authorities, effective steps had not been taken to identify the originators of the content or to ensure its removal from online platforms.
The respondents in the matter included the State of Karnataka, CEN Police Station of Bengaluru Central Division, media and broadcasting associations, as well as major technology and social media entities including Google LLC, Instagram, WhatsApp, and Meta Platforms Inc..
The case raised significant questions regarding the obligations of the State and digital intermediaries in addressing defamatory AI-generated content, balancing freedom of speech with protection of reputation, and ensuring accountability in the digital age. It also highlighted the emerging judicial response to deepfake technology and misinformation campaigns that can rapidly spread through social media ecosystems.
Arguments of the Parties:
The petitioners contended that the continued circulation of AI-generated and manipulated content depicting Veerendra Heggade and his family members amounted to a serious invasion of reputation, dignity, and privacy. They argued that the content was intentionally fabricated to create a false public narrative linking the Dharmasthala institutions and family members to criminal allegations that were still under investigation and had not been judicially established.
It was submitted before the Court that morphed videos, fabricated images, and manipulated media were being circulated across multiple online platforms with the objective of tarnishing the image of respected individuals and religious institutions. The petitioners maintained that the content was not merely speculative commentary or criticism but consisted of digitally altered material generated through artificial intelligence and editing tools designed to mislead the public.
The petitioners further argued that despite earlier judicial directions issued in Writ Petition No. 19382 of 2023, police authorities had failed to take prompt and meaningful action against the circulation of such objectionable material. According to them, representations had already been submitted to the authorities requesting identification of the persons responsible for creating and disseminating the content, blocking of relevant channels and accounts, and immediate removal of the offensive material from all platforms. However, no substantial action had followed.
The plea emphasised that the uncontrolled spread of manipulated digital content posed not only reputational harm but also threatened public order, institutional credibility, and societal trust. The petitioners argued that once such fabricated material gains circulation online, the damage becomes difficult to reverse because social media algorithms amplify sensational and controversial content irrespective of authenticity.
The petitioners also relied on the legal principle that the right to reputation forms an integral part of the right to life and personal liberty protected under Article 21 of the Constitution of India. It was contended that constitutional courts possess inherent powers to issue writs and directions for protection of fundamental rights where authorities fail to discharge their duties.
Another important contention raised by the petitioners was that digital intermediaries and social media platforms cannot remain passive spectators once they are notified about unlawful, defamatory, or manipulated content hosted on their platforms. The petition sought directions requiring such entities to remove the material within twenty-four hours and to cooperate with authorities in identifying the originators and disseminators of the allegedly fabricated content.
The petitioners additionally referred to previous judicial orders passed by Bengaluru courts restraining publication of defamatory content against Veerendra Heggade, his family members, institutions managed by them, and the Sri Manjunathaswamy Temple, Dharmasthala. According to the petitioners, despite these judicial protections, online circulation of objectionable content continued unabated through anonymous accounts, video channels, and AI-generated media.
On the other hand, the State Government and police authorities, represented by the Additional Government Advocate, submitted before the Court that they were prepared to take immediate and necessary steps to remove the contentious content from all platforms. However, the State sought reasonable time to coordinate with relevant authorities, media entities, and digital platforms to ensure compliance with any judicial directions issued by the Court.
The respondents did not seriously dispute the existence of objectionable and allegedly manipulated content online. Instead, the State assured the Court that law enforcement agencies would take effective measures to identify and address unlawful digital dissemination. The State also indicated that the technical nature of online takedowns and the involvement of multiple digital platforms required some operational coordination.
At the same time, the matter involved broader legal tensions concerning free speech and media reporting in matters of public interest. The underlying controversy regarding the alleged mass burial case had already become the subject of extensive public debate and ongoing criminal investigation by the SIT. The circulation of commentary, reports, and opinions on social media had therefore intersected with larger questions relating to freedom of expression under Article 19(1)(a) of the Constitution.
However, the petitioners distinguished ordinary criticism or reporting from AI-generated and manipulated visual content, arguing that fabricated material intended to deceive viewers falls outside constitutional protection and amounts to malicious misuse of technology.
The case also acquired additional complexity because of parallel proceedings involving media restrictions and criminal action against content creators. In April 2026, the Karnataka High Court had stayed criminal proceedings against YouTuber Sameer M.D., who operated the Dootha YouTube channel, in connection with a video relating to the Dharmasthala mass burial controversy. That proceeding highlighted the delicate balance courts must maintain between preventing defamatory misinformation and preserving legitimate journalistic or public discourse.
Court’s Judgment:
Justice S.R. Krishna Kumar, while disposing of the writ petition, observed that the authorities had failed to take adequate and effective action despite earlier judicial directions and representations submitted by the petitioners. The Court recognised the seriousness of the allegations concerning circulation of AI-generated, morphed, manipulated, and fabricated content relating to Veerendra Heggade and his family members.
The Court noted that the rapid spread of such digitally altered content through social media platforms, online media outlets, and internet URLs necessitated immediate intervention to prevent further harm. Taking note of the submissions made by the State Government that it would undertake necessary action if reasonable time was granted, the Court proceeded to issue explicit directions for immediate takedown and removal of objectionable material.
In its operative portion, the Court directed respondent authorities, including the State Government and police officials, to take “necessary, effective and immediate steps” to ensure that all AI-generated, morphed, manipulated, or fabricated images and video content depicting Veerendra Heggade and his family members are removed, erased, deleted, and taken down from all social media platforms, URLs, press and media outlets.
The Court specifically fixed a time period of one week from the date of receipt of the order for implementation of the directions. The order covered not only digital platforms but also media organisations and online publishers arrayed as respondents in the proceedings.
Although the order was concise, its implications are legally significant because it reflects judicial recognition of the dangers posed by deepfake technology and AI-generated misinformation. The Court’s intervention demonstrates an emerging judicial willingness to direct active digital enforcement measures where manipulated content threatens reputation and public confidence.
The judgment also indirectly reinforces the principle that intermediaries and authorities cannot remain passive once they become aware of unlawful online content. By directing immediate removal across all platforms, the Court signalled that technological complexity cannot become an excuse for administrative inaction where reputational harm is ongoing and substantial.
The order further illustrates the judiciary’s attempt to adapt traditional legal remedies to modern digital harms. Historically, defamation and reputational injury were addressed through civil suits, injunctions, or criminal complaints. However, AI-generated media and viral social media dissemination have fundamentally changed the speed and scale at which harmful content spreads. Courts are therefore increasingly required to issue urgent and technology-sensitive directions to contain digital damage before it becomes irreversible.
The Court’s intervention also aligns with broader constitutional principles protecting dignity and reputation as integral facets of Article 21. Indian courts have repeatedly recognised that the right to reputation is an inseparable component of the right to life and personal liberty. In the digital era, manipulated visual content can cause immediate reputational destruction even before facts are verified or investigations are completed.
At the same time, the case underscores the continuing legal challenge of balancing free speech with safeguards against misinformation and digital abuse. While freedom of expression remains constitutionally protected, the Court appeared to distinguish between legitimate public discourse and fabricated AI-generated content specifically designed to mislead viewers.
Importantly, the Court did not enter into findings regarding the truth or falsity of the allegations connected with the alleged mass burial case itself. Instead, the focus remained confined to preventing circulation of manipulated and fabricated media content pending investigation and legal proceedings.
The decision may have wider implications for future cases involving deepfakes, AI-generated videos, and digitally altered content targeting public figures, institutions, or private individuals. As artificial intelligence tools become increasingly accessible, courts across India are likely to encounter similar disputes concerning misinformation, privacy, reputation, and platform accountability.
The Karnataka High Court’s order therefore represents an important step in the evolving intersection between constitutional law, technology regulation, media accountability, and digital rights in India.