Bombay High Court Shields Suniel Shetty from AI Misuse with John Doe Order

In a significant ruling addressing the burgeoning threat of artificial intelligence, the Bombay High Court has granted actor Suniel Shetty urgent ad-interim protection, issuing a sweeping John Doe order to safeguard his personality rights against rampant online misuse, including AI-generated deepfakes and fraudulent endorsements.

MUMBAI – The Bombay High Court, in an order that underscores the judiciary's proactive stance against technological malfeasance, has provided actor Suniel Shetty with a robust legal shield against the unauthorized exploitation of his identity. Justice Arif S Doctor granted an ad-interim injunction restraining a wide array of known and unknown entities—collectively impleaded as 'John Doe/Ashok Kumar'—from infringing upon Shetty's personality rights through any medium.

The court's decision comes as a critical development in the evolving jurisprudence of personality rights in India, particularly as celebrities and public figures grapple with the challenges posed by generative AI. The infringing activities cited in Shetty’s plea included deepfake images, fraudulent brand endorsements, unauthorized merchandise, and impersonation on social media platforms.

Justice Doctor, in his observations, delivered a stark assessment of the issue, describing the material presented as a "lethal combination of a depraved mind and the misuse of technology." This powerful condemnation highlights the court's recognition of the severe harm such activities can inflict.

The matter is scheduled for a further hearing on November 17, 2025.

The Scope of Infringement: A Multi-Pronged Attack

Representing Shetty, Senior Advocate Dr. Birendra Saraf presented compelling evidence of the widespread and damaging nature of the misuse. The court was shown instances of deepfake images depicting the actor in inappropriate situations, including a fabricated image with a well-known actress and another with his own grandchild.

Saraf detailed the multifaceted infringement, stating, “These are deep-fake photographs and videos circulating... a real estate agency using his photograph as intervals, an astrology website which uses his photographs. A gambling website also featured him, and none of these were with his permission.” He further noted the sale of unauthorized merchandise, such as t-shirts and posters bearing Shetty's likeness.

The plea argued that this unauthorized use not only constituted a violation of Shetty's personality and privacy rights but also amounted to classic passing off, misappropriation of goodwill, and consumer deception. Shetty’s suit seeks ₹15 crore in damages for the harm caused to his reputation and brand value, contending that the misuse misleads the public into believing he endorses products and services with which he has no association.

Legal Analysis: Fortifying Personality Rights Against Digital Threats

The court's order is a landmark in its direct confrontation with AI-driven infringement. Justice Doctor observed that the unauthorized use of Shetty’s persona created a "false sense of endorsement or affiliation," directly misleading the public. The court's reasoning firmly roots the protection in fundamental rights, connecting the misuse to violations of dignity, privacy, and commercial interests.

"The unauthorised creation/uploading of deep fake images of the plaintiff on social media platforms constitutes a grave infringement not only of his personality rights but also of his right to live with dignity," the court order stated. "Equally, the unauthorised use of AI generated images of the plaintiff and his family members constitutes a blatant invasion of their privacy and their fundamental rights."

This observation reinforces the judicial trend of interpreting personality rights as an amalgam of the right to privacy under Article 21 of the Constitution and common law principles of passing off and publicity rights. By linking AI-generated content directly to a violation of fundamental rights, the court has provided a potent legal argument for future litigants.

The John Doe Order: A Necessary Procedural Tool

A crucial aspect of the ruling is the grant of a 'John Doe' (or 'Ashok Kumar') order. This type of injunction is issued against unknown or unidentifiable defendants, which is particularly vital in cases of online infringement where perpetrators often operate anonymously.

The court validated this approach, noting, "Given the clandestine and continuing nature of these activities and the ongoing harm, the Plaintiff has correctly impleaded Defendant No. 1, 'John Doe/Ashok Kumar,' to represent the entire class of such unknown persons whose identities cannot be presently ascertained."

This order empowers Shetty to serve the injunction on any entity found to be infringing his rights, even if they were not an original party to the suit. The court has also directed social media intermediaries like Meta Platforms and X Corp (formerly Twitter) to remove the infringing content within a week of notification and, upon request, to disclose subscriber details of the infringing accounts.

A Growing Trend in Celebrity Litigation

Suniel Shetty's case is not an isolated incident but part of a broader movement by public figures to legally define and defend their personas in the digital age. This follows a series of similar petitions filed in the Delhi High Court by prominent personalities such as Aishwarya Rai Bachchan, Abhishek Bachchan, and Karan Johar.

In each of these cases, the courts have granted interim relief, signaling a judicial consensus on the need to protect individuals from the unauthorized commercial exploitation of their identity. This wave of litigation is forcing a legal reckoning with the concept of 'personality' as a form of intellectual property that can be violated, diluted, and misappropriated through new technologies.

For legal practitioners, these cases offer a developing playbook on how to structure such claims, emphasizing the multifaceted nature of the harm—from reputational damage and invasion of privacy to direct commercial and contractual conflicts. The courts' willingness to grant broad, pre-emptive remedies like John Doe orders provides a powerful tool for IP and media law litigators in the fight against anonymous online infringers. As AI technology continues to advance, the principles articulated in Suniel Shetty's case will undoubtedly serve as a foundational precedent in the ongoing battle to protect personal identity and dignity online.