The Delhi High Court has granted ex parte ad interim injunction in favour of actor R. Madhavan, restraining multiple online entities from misappropriating his name, image, likeness and voice through AI-generated deepfake content, fake movie trailers, morphed pornographic material and unauthorised merchandise.
Justice Manmeet Pritam Singh Arora held that Madhavan’s personality attributes, including his name ‘Ranganathan Madhavan’/‘R Madhavan’ likeness, voice, image and other aspects of his persona, have acquired distinctiveness, goodwill and commercial value through decades of work, making them legally protectable. The Court observed that unauthorised AI-generated content falsely suggests endorsement, infringes personality and publicity rights, and causes irreparable harm to reputation and dignity.
The case stemmed from a suit alleging that several YouTube channels were circulating AI-generated deepfake trailers and videos, while certain websites hosted morphed pornographic content using the actor’s likeness. Unauthorised merchandise bearing Madhavan’s image was also being sold on online platforms. The suit was filed against nearly twenty defendants, including multiple YouTube channels creating AI-generated deepfake movie trailers and videos using the actor’s likeness, websites hosting morphed and pornographic content, online marketplaces facilitating sale of unauthorised merchandise, social media platforms, domain registrars, proforma defendents (Flipcart, Meta, Google, MEITY & DoT etc.) and John Doe entities involved in unidentified infringing activities.
Noting that celebrity status inherently vests a public figure with proprietary rights over his personality and associated attributes, the Court held that the plaintiff is entitled to “seek an injunction against the unauthorised use of these personality rights by third parties for their commercial gains.” The Court also held that the plaintiff is entitled to protect himself against objectionable, obscene, morphed and AI-generated deepfake content created by third parties, particularly where such content results in misappropriation of identity, false endorsement, and irreparable harm to dignity and reputation.
The Court restrained infringing defendants and John Doe entities from further exploitation of the actor’s persona and directed immediate takedown of infringing URLs.
While hearing the suit seeking the permanent injunction against misappropriation of personality and publicity rights, the Court dispensed with the issuance of summons to defendants who had already taken down the infringing content, while reserving liberty to the plaintiff to pursue them. The Court had directed proforma defendants to furnish Basic Subscriber Information (BSI) in respect of the John Doe entity within 3 weeks, while granting liberty to the plaintiff to file an amended memo of parties with process fee after receiving the BSI details, within one 1 week.
The matter has been listed before the Joint Registrar on February 10, 2026, and before the court on May 22, 2026.
Cased Referred
D.M. Entertainment Pvt. Ltd. v. Baby Gift House & Ors., 2003 (26) PTC 245 (Del)
Anil Kapoor v. Simply Life India & Ors. 2023 SCC OnLine Del 6914
Jaikishan Kakubhai Saraf alias Jackie Shroff v. The Peppy Store & Ors., 2024 SCC OnLine Del 3664
Appearances
Plaintiff- Ms. Swathi Sukumar, Sr. Adv. with Ms. Anushree Rauta, Mr. Shwetank Trikpathi, Mr. Devangiri Rai, Mr. Mohit Bangwal, Mr. Vidit Desai and Ms. Purvi Mehta, Advs.
Defendants- Mr. Varun Pathak, Mr. Vishesh Sharma and Ms. Prasidhi Agrawal, Advs. for D-17 Ms. Mamta Rani Jha, Ms. Shruttima Ehersa, Mr. Rohan Ahuja, Ms. Aiswarya Debardarshini and Ms. Jahanvi Agarwal, Advs. for D-18
