Personality Rights in India: What Delhi High Court Decisions Say About Names, Images, Voices and AI Misuse

By C&C Law Chambers Editorial Desk

A familiar face in an advertisement can make people trust a product. A convincing imitation of someone’s voice can make a false statement sound genuine. These are the problems behind many personality-rights cases: someone uses another person’s identity to sell, deceive, impersonate or humiliate.

The Delhi High Court decisions discussed below show that protection is important, but not unlimited. A fake endorsement is different from a news report. A harmful deepfake is different from a genuine tribute. Sharing a celebrity’s name does not necessarily prevent another person from honestly using their own name.

This article explains the particular decisions and orders identified below. Many granted only interim protection—a temporary order while the case continues—not a final decision after trial. Their individual directions should not be treated as a universal ban on mentioning or depicting public figures.

Privacy and consent: Phoolan Devi

In Phoolan Devi v. Shekhar Kapoor, decided on 1 December 1994, the dispute concerned the film Bandit Queen and its depiction of intimate and traumatic events in Phoolan Devi’s life. The Court examined whether the agreements and correspondence relied upon by the filmmakers established her consent to the disputed portrayal.

It did not accept, at that preliminary stage, that the documents necessarily authorised the intimate depiction in question. Whether informed consent had actually been given required evidence. The Court restrained exhibition pending disposal of the suit. The important distinction is between agreeing to a project and consenting to every intrusive depiction within it. This describes the 1994 interim order, not a claim that its exhibition restraint remains operative today. [Phoolan Devi v. Shekhar Kapoor, 1994 SCC OnLine Del 722, paragraphs 38–40 and 42](https://indiankanoon.org/doc/793946/).

Selling a celebrity’s identity: Daler Mehndi and Titan

In D.M. Entertainment Pvt. Ltd. v. Baby Gift House, decided on 29 April 2010, the defendants sold dolls resembling Daler Mehndi which played his songs. The Court treated the unauthorised exploitation of his recognisable persona and the impression of endorsement as actionable. It granted a permanent injunction, ₹1 lakh in damages and costs. The ₹1 lakh was damages; it was not the value or description of the injunction.

The Court also distinguished commercial exploitation from caricature, lampooning and parody. The decision therefore should not be reduced to a rule that every representation of a celebrity requires permission. [D.M. Entertainment, 2010 SCC OnLine Del 4790, paragraphs 13–18, judgment PDF](https://neetiniyaman.com/wp-content/uploads/2025/07/Daler-Mehndi.pdf).

In Titan Industries Ltd. v. Ramkumar Jewellers, decided on 26 April 2012, a jeweller used advertising material featuring Amitabh and Jaya Bachchan associated with Titan’s campaign. The Court explained the significance of an identifiable personality and unauthorised endorsement. The defendant agreed to the injunction, and Titan gave up its remaining reliefs. A permanent injunction followed. This was not an award of damages after a contested assessment of their amount. [Titan Industries, 2012 SCC OnLine Del 2382, paragraphs 12 and 15–21](https://indiankanoon.org/doc/181125261/).

A famous name is protected—but not owned in every context

In Arun Jaitley v. Network Solutions Pvt. Ltd., decided on 4 July 2011, the dispute concerned a domain name incorporating Arun Jaitley’s name. The Court recognised that a personal name can acquire a distinctive identity and goodwill. It granted relief against the disputed domain-name use, including transfer. The reasoning concerned the particular name, its established association and the defendants’ conduct; it did not give every person exclusive rights over all uses of a common name. [Arun Jaitley, 2011 SCC OnLine Del 2660, paragraphs 23, 29–32 and the concluding directions](https://indiankanoon.org/doc/754672/).

The limit is illustrated by Gautam Gambhir v. D.A.P. & Co., decided on 13 December 2017. The restaurant owner was himself named Gautam Gambhir. The Court found no sufficient basis to conclude that he had represented his restaurants as belonging to, or being associated with, the cricketer. He used his own photographs to identify himself.

The Court observed:

“an individual is entitled to carry on his business in his ‘own’ name so long as he does not do anything more to cause confusion with the business of another and if he does so honestly/bonafide.”

The suit was dismissed. Honest use of one’s own identity was not displaced simply because a celebrity had the same name. [Gautam Gambhir, 2017 SCC OnLine Del 12167, paragraphs 9–10](https://indiankanoon.org/doc/106318101/).

Rajat Sharma: a particular advertisement, not a ban on criticism

In Rajat Sharma v. Ashok Venkatramani, the order of 11 January 2019 concerned a rival news-channel advertisement referring to Rajat Sharma and other television personalities. The Court found a preliminary case for relief and restrained the impugned advertisement, including its use in print and television, with directions concerning hoardings. Its subject was the advertisement before the Court; it was not a general prohibition on discussing or criticising the journalist. [Rajat Sharma, CS(COMM) 15/2019, paragraphs 5 and 8–9, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/15/2019/11-01-2019).

Anil Kapoor: protection against misuse without silencing genuine expression

In Anil Kapoor v. Simply Life India, the order of 20 September 2023 addressed unauthorised merchandising, manipulated content and exploitation of the actor’s identity. The Court stated:

“Using a person’s name, voice, dialogues, images in an illegal manner, that too for commercial purposes, cannot be permitted.”

That observation must be read with paragraph 38, which recognises space for news, satire, authentic parody and genuine criticism. The Court was concerned with uses crossing into unlawful exploitation and harm, including offensive manipulation. It granted interim protection; it did not declare every reference to an actor unlawful. [Anil Kapoor, 2023 SCC OnLine Del 6914, paragraphs 38–47, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/652/2023/20-09-2023).

Jackie Shroff: why the Court treated a tribute differently

In Jaikishan Kakubhai Saraf alias Jackie Shroff v. The Peppy Store, decided on 15 May 2024, the Court considered several kinds of allegedly unauthorised content. It granted interim protection against specified misuse but did not immediately restrain a “Thug Life” video assembled from public interview clips.

The Court considered whether that video could be a creative tribute and warned against protection that “stifles freedom of expression”. It wanted the relevant defendant’s response before deciding that part of the dispute. That was a refusal of immediate, one-sided relief—not a final ruling that every monetised fan video is lawful. [Jackie Shroff, 2024 SCC OnLine Del 3664, paragraphs 19–28, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/389/2024/15-05-2024).

Digital Collectibles: the appellate qualification matters

Digital Collectibles Pte. Ltd. v. Galactus Funware Technology Pvt. Ltd. is frequently discussed in connection with digital player cards and personality rights. However, any reliance on the 26 April 2023 interim decision must account for the subsequent appeal.

The Division Bench disposed of the appeals on 15 April 2024 after the Striker platform had closed its relevant services. It expressly stated that the challenged interim judgment would neither operate as res judicata nor constitute a precedent, and preserved the parties’ contentions. The order was reproduced in the Single Judge’s order of 22 July 2024. It would therefore be misleading to present the earlier reasoning as a definitive appellate approval of unrestricted commercial use of sports personalities. [Digital Collectibles, CS(COMM) 108/2023, order of 22 July 2024 reproducing the appellate order, especially paragraphs 4–7](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/108/2023/22-07-2024).

Fake medical and investment endorsements

In Dr. Devi Prasad Shetty v. Medicine Me, the order of 28 November 2024 concerned allegedly manipulated material using the doctor’s identity in connection with medical products. The Court found a preliminary case and granted interim restraints and removal directions. The distinction matters: the plaintiffs’ submissions about health risks were not findings reached after trial. The Court’s operative response was to the apparent misuse and need for immediate protection. [Devi Prasad Shetty, CS(COMM) 1053/2024, paragraphs 38–45, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/1053/2024/28-11-2024).

In Ankur Warikoo v. John Doe, the order of 26 May 2025 addressed deepfake investment advertisements using Warikoo’s identity. The Court recognised the apparent harm both to his reputation and to viewers who might mistake the advertisements for genuine recommendations. It granted interim restraints and specified removal directions, including a 36-hour mechanism for the identified platform and circumstances. That deadline was a case-specific direction, not a universal time limit imposed on every website by this decision. [Ankur Warikoo, CS(COMM) 514/2025, paragraphs 51–58, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/514/2025/26-05-2025).

AI impersonation: Vishnu Manchu and Sadhguru

In Vishnu Manchu v. Arebumdum, the Court’s order of 1 October 2024 granted interim protection against specified defamatory and unauthorised uses of the actor’s identity, including technologically manipulated content. The operative directions were temporary; a preliminary finding in support of an injunction was not a final finding against every defendant. [Vishnu Manchu, CS(COMM) 828/2024, paragraphs 43–48, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/828/2024/01-10-2024).

In Sadhguru v. Igor Isakov, the order of 30 May 2025 addressed unauthorised identity use, including AI-generated material. The Court granted interim relief and a mechanism for notifying further infringing material. That mechanism also allowed disputed requests to return to court. The important point is that later takedown requests were not simply a licence to remove anything the claimant disliked. [Sadhguru, CS(COMM) 578/2025, paragraphs 43–46, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/578/2025/30-05-2025).

Aishwarya Rai Bachchan and Abhishek Bachchan: commercial harm and dignity

In Aishwarya Rai Bachchan v. Aishwaryaworld.com, the order of 9 September 2025 recognised the apparent risk that unauthorised uses could lead people to believe that the actor endorsed goods or services. It also addressed manipulated content and injury to dignity. Interim restraints and identified takedown directions followed. [Aishwarya Rai Bachchan, CS(COMM) 956/2025, paragraphs 35–39, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/956/2025/09-09-2025).

In Abhishek Bachchan v. The Bollywood Tee Shop, the order of 10 September 2025 similarly dealt with unauthorised commercial use and derogatory manipulation of identity. The Court’s concern extended beyond lost endorsement revenue to privacy and dignity. Again, this was interim protection on a preliminary assessment, not a final damages judgment. [Abhishek Bachchan, CS(COMM) 960/2025, paragraphs 35–39, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/960/2025/10-09-2025).

Sunil Gavaskar: falsely attributed statements and merchandising

In Sunil Manohar Gavaskar v. Cricket Tak, the order of 23 December 2025 addressed alleged unauthorised merchandising and statements attributed to the cricketer which he denied making. The Court granted interim restraints and specific removal directions. It also preserved a route for a person claiming that their material was non-infringing to seek modification. This is important because relief against fabricated statements should not be confused with ownership of every discussion about a sportsperson. [Sunil Gavaskar, CS(COMM) 1329/2025, paragraphs 36–40, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/1329/2025/23-12-2025).

Kumar Sanu and Jubin Nautiyal: AI voices and the limits of relief

In Kumar Sanu v. Jammable Ltd., the order of 15 October 2025 granted targeted interim protection against unauthorised exploitation, including AI-related voice use and specified commercial material. But the Court did not grant every requested takedown. It declined immediate relief concerning certain publicly available biographical information and a particular GIF where infringement was not apparent. Those refusals are part of the decision, not exceptions that can be omitted from its account. [Kumar Sanu, CS(COMM) 1097/2025, paragraphs 43–49, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/1097/2025/15-10-2025).

In Jubin Nautiyal v. Jammable Ltd., the order of 19 February 2026 granted interim protection covering unauthorised AI-generated or synthetic exploitation of the singer’s identity and specified merchandising. The directions addressed the uses before the Court; they should not be expanded into a claim that a singer owns every similar sound or musical style. [Jubin Nautiyal, CS(COMM) 166/2026, paragraphs 35–36, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/166/2026/19-02-2026).

Hrithik Roshan: protection did not mean removing every fan profile

In Hrithik Roshan v. John Doe, the order of 15 October 2025 granted interim relief against specified merchandise, impersonation and manipulated content. But the Court distinguished individual offending posts from entire profiles. Some URLs were expressly excluded from takedown. For certain fan profiles, it contemplated identifying and hearing the operators before further orders.

The decision shows why a claim needs to identify the actual misuse. Protecting a person’s identity does not automatically justify removing every account or fan page mentioning them. [Hrithik Roshan, CS(COMM) 1107/2025, paragraphs 35–42, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/1107/2025/15-10-2025).

Janhvi Kapoor: why thousands of links required classification

In Janhvi Kapoor v. John Doe, the order of 11 August 2026 considered a request concerning 6,884 URLs. The Court did not treat the entire list as one undifferentiated category. It required segregation and addressed 552 URLs which, on its preliminary examination, contained pornographic material. Removal directions were issued for that identified category.

The lesson from that order is precision: sexually explicit manipulation, merchandising and other kinds of online use cannot simply be assumed to raise identical issues. This account describes the August order, not a final disposition of the broader suit. [Janhvi Kapoor, CS(COMM) 868/2026, paragraphs 27–32, official order](https://delhihighcourt.nic.in/app/downloadOrderbByDate/CS%28COMM%29/868/2026/11-08-2026).

After death: what the Sushant Singh Rajput case actually decided

In Krishna Kishore Singh v. Sarla A. Saraogi, decided on 11 July 2023, Sushant Singh Rajput’s father sought to restrain a film by relying, among other things, on the deceased actor’s personal rights. The Court observed:

“The rights ventilated in the plaint - i.e., the right to privacy, the right to publicity and the personality rights which vested in SSR, are not heritable. They died with the death of SSR. The said rights, therefore, did not survive for espousal by the plaintiff.”

The injunction application was dismissed, while the damages claim remained available for determination in the suit. The quoted finding concerns the personal rights asserted in that case. It should not be rewritten as a declaration that all copyright, trademarks or other separately owned assets necessarily disappear when their owner dies. [Krishna Kishore Singh, 2023:DHC:4631, paragraph 21.2 and paragraphs 23–25](https://indiankanoon.org/doc/71066966/).

Conclusion: protection from misuse, not control over every mention

The central distinction is between discussing a person and appropriating their identity. The decisions provide strong examples of relief against fake endorsements, deceptive impersonation, unauthorised commercial exploitation and harmful manipulated content. They also show why the actual facts matter: an honest namesake, a creative tribute, biographical information and a fan profile cannot automatically be treated like a fraudulent advertisement.

Anyone relying on these cases should identify what the court actually ordered, which content it addressed and whether its decision was interim or final. The existence of a personality-rights claim does not dispense with that examination. Neither does the use of AI turn every depiction into infringement without considering its content, purpose and effect.

Sources and scope

Judgments and orders are linked beside each discussion. This is a case-based explanation of those identified decisions, not an exhaustive catalogue of all Delhi High Court personality-rights litigation or a certification that every interim direction remains unchanged.

This article provides general information, not legal advice for a particular dispute.

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