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Personality Rights Cannot Extinguish Parody: Delhi HC Grants PW’s Alakh Pandey Limited Interim Protection in Personality Rights Suit

Personality Rights Cannot Extinguish Parody: Delhi HC Grants PW’s Alakh Pandey Limited Interim Protection in Personality Rights Suit

Alakh Pandey v. John Doe(s) & Ors., CS(COMM) 835/2026 [Order dated August 05, 2026]

Personality Rights and Parody

The Delhi High Court has granted ex-parte ad-interim protection to educator and Physics Wallah founder Alakh Pandey against online content allegedly infringing his personality and publicity rights, including sexually vulgar portrayals, unauthorised commercial exploitation of his persona and impersonation.

Justice Anup Jairam Bhambhani observed that the plaintiff had made out a prima facie case in respect of three specific categories of alleged violations. The Court, however, cautioned that the concept of personality rights claimed in the suit could be “over broad and therefore susceptible to misapplication.”

The Court said personality rights cannot be invoked to prevent dissemination of information concerning wrongdoing or to extinguish forms of expression such as caricature, lampooning or parody merely because they involve an individual’s persona. The Court observed:

“Personality rights are not deployed to prevent dissemination of information in relation to wrongdoing; or to extinguish an entire genre of expression including caricature, lampooning or parady which may not amount to commercial exploitation of an individual’s personality or publicity rights.”

Proceeding with this caution, the Court limited the protection to three categories of alleged violations: portrayal of Pandey in a sexually vulgar manner; monetisation of his personality for gain without a licence or right to do so; and impersonation of Pandey.

The Court found that Pandey had established a prima facie case to this limited extent and that the balance of convenience also lay in his favour. It further held that failure to grant interim protection appeared likely to cause irreparable loss and injury to him.

Accordingly, the Court passed an ex-parte ad-interim injunction against Defendants Nos. 2, 3, 4, 7, 8, 13, 14, 15, 16, 18, 19 and 20, restraining them from using or exploiting Pandey’s name, image, likeness, voice and other aspects of his persona in the manner complained of.

The Court also directed Defendants Nos. 21 to 31, which include intermediaries and other entities, to remove or take down the specified content and disclose details including the identities, addresses, contact details and payment particulars of the concerned defendants.

The order followed Pandey’s submission of a tabulated list of allegedly infringing URLs. The URLs were categorised into three groups: content containing sexually vulgar material, content that commercially exploited his personality rights, and content allegedly impersonating him.

The Court permitted Plaintiff to bring to its notice mirror, alphanumeric or redirect websites of the identified defendant websites. Such websites may be technically verified by the concerned ISP or domain-name registrar and, if found to be mirror or redirect sites, the injunction may be enforced against them on a pro-tem basis. The Court clarified that ISPs and domain registrars cannot block websites merely on a party’s request; their role is limited to technically verifying mirror, alphanumeric or redirect websites of those already covered by the injunction.

The suit has been registered and the Court issued summons in the suit and directed the defendants to file their written statements within 30 days. The matter is listed before the Joint Registrar on November 6, 2026 for completion of pleadings and admission/denial of documents.

Also Read Delhi HC Declines Blanket Takedown Order of Janhvi Kapoor’s Personality Rights Suit; Orders Removal of 552 Pornographic URLs

Appearances

Plaintiff: Mr. J. Sai Deepak, Sr. Advocate with Mr. Mohit Goel, Mr. Abhishek Kotnala, Mr. Kartikeya Tandon, Ms. Urvashi Singh, Mr. M. Mazumndar and Ms. Sidhi Pramod R., Advocates.

Defendants: Mr. Aditya Gupta, Mr. Vani Kaushik, Ms. Sunidhi Agrahari, Advocates for D-23. Ms. Maitreyee Jagat Joshi, CGSC with Ms. Bhawna, GP, Mr. Ayush Kasana, Ms. Kushi, Ms. Shikha Yadav, Advocates for D-33 and 34. Mr. Manisha Agrawal Narein, CGSC with Mr. Nipun Jain, GP for DoT and Meity. Mr. Madhav Khosla, Advocate for D22.

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Alakh Pandey v. John Doe(s) & Ors.

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