By Shilpi Sharan and Huda Jafri
Introduction
In recent years, there has been a sudden surge in disputes over personality rights, reflecting the growing commercial and digital value of individual identities. Celebrities and public figures are increasingly confronting unauthorized use of their names, images, voices, and personas often amplified by social media, AI technologies, and global online platforms.
Personality rights sometimes referred to as publicity rights protect an individual’s name, image, voice, likeness, reputation, and other distinctive personal attributes. These rights have gained particular prominence through a series of high-profile cases involving the Bachchan family Aaradhya Bachchan, Aishwarya Rai Bachchan, and Abhishek Bachchan. Even before these, the senior Bachchan had been at the centre of landmark litigation in which the Delhi High Court issued one of the first detailed injunctions against AI-based voice cloning and unauthorized merchandise.
The 2025 case of Abhishek Bachchan v. Bollywood Tee Shop & Ors. brought the issue into fresh focus. Hon’ble Justice Tejas Karia noted that Mr. Bachchan’s persona including his name, photographs, voice, and signature was being exploited without consent, particularly through AI-driven tools. For the first time, the Court directly engaged with the implications of AI, deepfakes, and digital impersonation on reputation, dignity, and commercial goodwill.
While personality rights are well recognized by courts, they remain uncodified. As a result, judicial decisions continue to balance privacy, commercial exploitation, and technological challenges on a case-by-case basis. The Bachchan family cases Aaradhya (2023), Aishwarya (2025), and Abhishek (2025) together reflect this evolving and increasingly relevant judicial approach.
- Personality Rights in India: Concept and Status
Definition
Personality rights are the legal rights of an individual to control the commercial and dignitary use of their name, image, likeness, voice, signature, and other distinctive personal attributes.
They can be broadly classified into:
- Right to Privacy (under Article 21)
- Right against Commercial Exploitation (protecting the commercial value of one’s persona)
Emerging Challenges- AI and deepfake technologies.
- Anonymity of online infringers.
- Cross- border violations.
Abhishek Bachchan v. The Bollywood Tee Shop & Ors.[1]
Case Background
In 2025, Mr. Abhishek Bachchan, a leading actor in Indian cinema and a public figure with significant commercial and social influence, initiated legal proceedings before the Hon’ble Delhi High Court. The Plaintiff sought protection of his personality rights in light of extensive unauthorized commercial exploitation of his name, image, and likeness across online and offline platforms.
The suit targeted multiple categories of infringers, including:
- E-commerce sellers and merchandise distributors: Allegedly marketing T-shirts, mugs, posters, stickers, and other memorabilia bearing the Plaintiff’s image, signature, or name without authorization, thereby misleading consumers into believing the products were endorsed by him.
- Digital content creators and AI platforms: Hosting or generating AI-based content, including videos and images that depicted the Plaintiff in contexts that were sometimes inappropriate, derogatory, or commercially exploitative.
- Online intermediaries and platforms: Including Google LLC (Defendant No. 15), responsible for hosting and disseminating such content, potentially enabling the widespread circulation of infringing material.
- Government authorities: The Ministry of Electronics & IT and the Department of Telecommunications (Defendants 16–17), included to ensure prompt compliance with any court orders regarding content takedown and enforcement measures.
- Unknown or unidentified infringers: Designated as Defendant No. 18, covering future or as-yet-unidentified actors engaging in similar misconduct.
The Plaintiff contended that the defendants were not only profiting from the unauthorized use of his persona but were also harming his goodwill, public image, and personal dignity, creating the need for immediate judicial intervention.
Legal Claims
The Plaintiff’s complaint advanced several intertwined legal claims:
- Personality Rights / Publicity Rights:
The Plaintiff alleged misappropriation of his name, voice, likeness, signature, and other distinctive personal attributes. The suit emphasized that such rights are not only commercially valuable but also central to a celebrity’s personal and professional identity. - Passing Off:
The defendants’ actions, according to the Plaintiff, created a likelihood of consumer confusion, implying endorsement or association with the Plaintiff without consent. This constituted actionable passing off under common law principles recognized by Indian courts. - Moral Rights under Copyright Law (Section 57, Copyright Act, 1957):
The creation and dissemination of AI-generated content distorted the Plaintiff’s persona, potentially harming his honor and reputation as a public figure and artist. - Right to Privacy and Reputation (Article 21, Constitution of India):
Unauthorized and unsavoury depictions of the Plaintiff were claimed to violate fundamental rights, as they infringe upon the Plaintiff’s dignity, privacy, and reputation, core aspects of Article 21 jurisprudence in India. - Interim Relief:
Given the ongoing and imminent threat of further exploitation, the Plaintiff sought urgent ex-parte injunctions restraining the sale, dissemination, and creation of any content using his persona.
Defendants and Infringing Activities
The Court meticulously recorded the types of infringing activities attributed to different defendants:
| Category | Defendants | Alleged Activity |
| Merchandise sale | D1–D9, D18 | Unauthorized sale of T-shirts, mugs, posters, and stickers bearing Plaintiff’s image, signature, and name for commercial gain |
| AI-generated content | D10–D12, D18 | Creation of AI-generated images and videos featuring Plaintiff alongside other celebrities, without authorization |
| Unsavoury/explicit AI content | D13–D14, D18 | Generation of content depicting Plaintiff in sexually suggestive or otherwise derogatory contexts |
| Platform hosting | D15 (Google/YouTube) | Hosting and facilitating the dissemination of infringing content, including AI-generated videos, without removing them despite notice |
| Government facilitation | D16–D17 | Providing regulatory oversight to ensure compliance with content takedown orders and facilitate enforcement |
The Court observed that many defendants structured their commercial operations specifically to monetize the Plaintiff’s persona without consent, often prioritizing profit over quality control or ethical considerations. This heightened the risk of irreparable reputational harm.
Court’s Observations
Upon evaluating the pleadings, evidence, and supporting affidavits, the Hon’ble Court made several key observations:
- Broad Scope of Personality Rights:
The Court recognized that personality rights extend beyond mere name and image. They encompass voice, signature, performances, and other uniquely identifiable personal traits, all of which are both commercially and morally protectable. - Prima Facie Case and Balance of Convenience:
The Plaintiff demonstrated a strong prima facie case, establishing that continued exploitation could cause irreparable economic and reputational damage. The balance of convenience clearly favored the Plaintiff. - Technological Misuse and AI Risks:
The Court acknowledged that AI-generated deepfake content introduces new dimensions of harm, including rapid dissemination, difficulty of traceability, and higher potential for reputational injury. - Free Speech versus Commercial Exploitation:
While incidental use, parody, or criticism may be legally permissible, deliberate commercial exploitation without consent amounts to passing off and misappropriation. - Specificity in Takedown Orders:
The Court declined to issue blanket injunctions covering all possible infringements, noting that such orders could be impractical to enforce. Instead, URL-specific injunctions were mandated, ensuring clarity, precision, and enforceability.
Orders Passed
The Hon’ble Court granted ad-interim ex-parte relief as follows:
- Defendants 1–14 and 18:
- Prohibited from using Plaintiff’s name, image, likeness, or signature for any commercial or personal purpose.
- Prohibited from creating, generating, or distributing AI/deepfake content depicting the Plaintiff.
- Required to remove or disable infringing URLs within 72 hours of notice.
- Platform Defendant (Google/YouTube, D15):
- Directed to take down infringing content immediately.
- Required to submit subscriber and channel operator information in a sealed cover within seven days for enforcement purposes.
- Government Authorities (D16–17):
- Directed to issue instructions to ensure prompt compliance with Court orders and facilitate cooperation between parties and platforms.
The Bachchan Family Personality Rights Cases
The Bachchan family’s legal battles have significantly influenced the landscape of personality rights in India. These cases encompass a range of issues, from unauthorized commercial use to the challenges posed by emerging technologies like AI and deepfakes.
- Amitabh Bachchan v. Rajat Nagi & Ors. (2022)[2]
Background:
In 2022, Amitabh Bachchan filed a lawsuit against Rajat Nagi and others for the unauthorized use of his name, image, voice, and catchphrases in various online platforms and merchandise. The defendants had been exploiting Bachchan’s persona without consent, leading to potential misrepresentation and commercial exploitation.
Court’s Observations:
The Hon’ble Delhi High Court recognized that a celebrity’s identity holds significant commercial value and that unauthorized use constitutes a violation of personality rights. The court issued an ad-interim ex-parte injunction, restraining the defendants from further misuse of Bachchan’s persona.
- Aaradhya Bachchan v. YouTube Channels[3], 2023
Background:
The plaintiff, being a minor and daughter of Abhishek Bachchan and Aishwarya Rai Bachchan, had been the subject of numerous false news reports and YouTube videos. These videos circulated false rumours about her health condition, some even suggesting that she was critically ill or hospitalized.
Court’s observations:
The Hon’ble Delhi High Court strongly criticized the circulation of misinformation about a child, noting that such actions violated the right to privacy, dignity, and protection from defamation. It held that freedom of speech does not extend to spreading baseless and harmful rumours that can affect a minor’s life.
- Aishwarya Rai Bachchan v. Aihwaryaworld.com & Ors[4], 2025
Background:
Over the years, Aishwarya Rai Bachchan has been subjected to several instances of unauthorized use of her image and likeness in advertisements, merchandise, and online circulation. In one such dispute, she sought injunctions against parties misusing her photographs for commercial purposes without consent.
Court’s observations:
The courts recognized that a public figure’s image cannot be commercially exploited without authorization. Using a celebrity’s photographs in indecent or false ways could amount not only to infringement of personality rights, but also to defamation and violation of privacy.
The Bombay High Court granted injunction against unauthorized use of Aishwarya’s images and likeness. It reinforced the commercial control aspect of personality rights.
- Other Recent Cases
- Asha Bhosle v. Mayk Inc. & Ors. Bombay High Court, 29 September 2025[5]
Background:
Renowned playback singer Asha Bhosle filed a lawsuit against two U.S.-based AI companies and private e-commerce site owners for unauthorized use of her voice through AI voice cloning. The defendants allegedly created illicit voice models by modifying her original recordings to replicate her voice, singing style, and vocal techniques without authorization. These voice models were made available to the public, allowing the generation of audio content mimicking her, and were commercially exploited via online marketplaces.
Court’s Observations:
Justice Arif Doctor of the Bombay High Court emphasized that enabling voice cloning of a celebrity without consent constitutes a violation of their personality rights, as it exploits their identity and voice, integral to their public persona. The court noted the defendants’ failure to appear, which supported Bhosle’s claim. Emphasizing the balance of convenience in her favor, the court determined she would suffer irreparable harm without relief. It ordered the removal of infringing content from the e-commerce platforms and directed the video-sharing service to share seller information upon request and remove specific links, as confirmed by Google LLC’s counsel.
Significance:
This case underscores the judiciary’s proactive stance in protecting celebrity identity in the digital age, particularly concerning AI-generated content.
- Nagarjuna Akkineni v. Various Online Platforms Delhi High Court, September 2025[6]
- Naresh Trehan / Medanta (Global Health Ltd. v. John Doe & Ors.) Delhi High Court, 8 January 2025[7]
Background:
Dr. Naresh Trehan, a renowned cardiac surgeon, was depicted in misleading deepfake videos circulating on social media and WhatsApp groups, where he was shown giving medical advice and propagating natural remedies to cure urological problems. The videos were created using AI, Photoshop, and voice-over techniques and featured his hospital chain trademark MEDANTA. The videos had been widely circulated, liked by 6,400 accounts, and viewed more than 1.1 million times.
Court’s Observations:
The Hon’ble Delhi High Court issued John Doe orders directing unidentified entities to take down the deepfake videos on Facebook featuring Medanta Hospital’s trademark and its chairperson Dr. Naresh Trehan. The court recognized the unauthorized use of Dr. Trehan’s likeness and the potential harm to his reputation and the hospital’s goodwill.
Background:
Telugu actor Nagarjuna secured interim protection against unauthorized AI-generated content and merchandise. The court ordered the removal of identified URLs and emphasized the risks posed by fabricated digital content.
Court’s Observations:
The Delhi High Court recognized the unauthorized use of Nagarjuna’s name, voice, and image through AI technologies. It issued orders to remove infringing content and highlighted the need for protective measures against digital impersonation.
Significance:
This ruling underscore the growing concern over the misuse of celebrity identities in India’s digital age and the judiciary’s role in safeguarding personality rights.
Conclusion
Recent orders whether involving the Bachchan family, Asha Bhosle, Jackie Shroff, Karan Johar, Nagarjuna, Dr. Naresh Trehan or others show Indian courts reacting promptly to the new risks posed by digital platforms and AI technologies. Courts are increasingly prepared to protect dignity, commercial value, and digital identity, while also weighing free-speech concerns and practical enforcement limits.
These decisions collectively illustrate judicial innovation, but they also point towards a complementary role for policy and legislative action to provide clarity, consistency and predictable enforcement pathways in the digital age.
[1] CS(COMM) 960/2025
[2] CS(COMM) 819/2022, Delhi High Court
[3] (2023) 6 HCC (Del) 727
[4] CS(COMM) 956/2025
[5] Interim Application (L) No. 30382 of 2025 in Commercial IP Suit (L) No. 30262 of 2025
[6] 2025 SCC OnLine Del 6331.
[7] CS(COMM) 6/2025