Delhi High Court Restrains AI-Generated Film for Unauthorized Use of Personality Rights

Introduction

In a significant ruling on the evolving intersection of artificial intelligence (AI) and personal rights, the Delhi High Court has granted an ex parte ad-interim injunction to 21-year-old Akira Nandan, son of Andhra Pradesh Deputy Chief Minister and actor Pawan Kalyan, restraining the defendants from exploiting his name, image, likeness, and persona through unauthorized AI-generated content. The court's order, dated January 23, 2026, in the case Akira Nandan v. Sambhawaami Studios LLP & Ors. (CS(COMM) 68/2026), addresses the creation and dissemination of a full-length AI film titled AI Love Story , which portrayed Nandan as the lead character without his consent. Justice Tushar Rao Gedela emphasized the irreparable harm to the plaintiff's reputation and privacy, invoking principles of personality rights, publicity rights, and copyright under Indian law. This decision underscores the judiciary's proactive stance against deepfake misuse, particularly in the entertainment industry, and directs social media platforms like YouTube and Meta to remove infringing content and disclose user details.

The suit, filed as a commercial dispute, highlights the rapid proliferation of AI-generated media, with the Telugu version of the film amassing over 1.1 million views on YouTube as of January 22, 2026, before being made private. Nandan, a budding figure in the Telugu entertainment scene with contributions to films like OG and a personal YouTube channel "thechordfather" boasting 90,400 subscribers, argued that such exploitation not only breaches his moral and publicity rights but also enables public deception and potential fraud. The court's intervention sets a precedent for protecting emerging public figures from AI-driven impersonation, amid growing concerns over deepfakes in India.

Case Background

Akira Nandan, residing in Hyderabad and pursuing studies, hails from the prominent Konidela family, synonymous with Telugu cinema and politics. His father, Pawan Kalyan (also known as Power Star), is a celebrated actor and Deputy Chief Minister of Andhra Pradesh, while his mother, Renu Desai, is an actress, director, and producer. Nandan's uncles include actors Chiranjeevi and Nagendra Babu, and cousins like Ram Charan and Sai Dharam Tej further cement the family's influence. At 21, Nandan has carved a niche with a cameo in the film Ishq Wala Love , musical contributions to OG , and his YouTube channel focused on piano covers, which has garnered over 2.6 lakh views. He is also trained in martial arts and engages in social activities, earning nicknames like "Power Star Kid" and "Rising Star Kid Akira" in media discourse.

The dispute arose when defendant no. 1, Sambhawaami Studios LLP, allegedly produced and uploaded AI Love Story —touted as the "world's first global AI movie"—on YouTube without Nandan's authorization. The one-hour sci-fi romance thriller used AI morphing and deepfake technology to replicate Nandan's facial features, voice, mannerisms, and persona, depicting him in fabricated intimate and romantic scenes. Multiple versions were circulated: the Telugu dubbed edition drew 1,109,255 views, the English version 24,354 views, and promotional shorts and trailers further amplified reach. Additional infringing content included fake social media profiles on Instagram, Facebook, and X (formerly Twitter) impersonating Nandan, some soliciting donations for fabricated causes like cancer treatments, raising alarms of fraud.

Nandan filed the suit in the Delhi High Court, seeking permanent injunctions against the defendants, including Sambhawaami Studios (D-1), Google LLC/YouTube (D-2), Meta Platforms Inc. (D-3), X Corporation (D-4), and unknown John Does. He claimed violations of his personality rights, right to privacy under Article 21 of the Constitution, moral rights and copyright under the Copyright Act, 1957, and publicity rights as recognized in common law. The legal questions centered on: (1) whether unauthorized AI-generated deepfakes constitute infringement of personality and publicity rights; (2) the extent of platforms' liability under the Information Technology Act, 2000, for hosting such content; and (3) the need for interim relief to prevent irreparable harm given the content's viral spread. The case timeline began with the film's upload in early 2026, prompting Nandan's suit and applications for exemptions from pre-institution mediation and advance notice, granted due to urgency.

News reports from sources like NDTV and Bar and Bench corroborated the family's concerns, noting over 100 fake accounts across platforms exploiting Nandan's identity for views, likes, and monetary gains. One Facebook post, for instance, falsely sought donations in his name for a child's treatment, deceiving fans and risking financial misuse.

Arguments Presented

As this was an ex parte hearing, arguments were primarily from the plaintiff's side, represented by Senior Advocate J. Sai Deepak, along with advocates Himanshu Deora, Rahul Mehta, and others from King Stubb & Kasiva. Nandan contended that the defendants' actions prima facie violated his fundamental rights to privacy and dignity, protected under Article 21, by intruding into his personal sphere through manipulated content. He argued that the AI film not only misappropriated his distinctive persona—built through family lineage, on-screen appearances, and social media presence—but also caused reputational damage by portraying him in unauthorized romantic scenarios, potentially misleading the public into believing he endorsed the project.

Deepak emphasized the commercial exploitation angle, noting Sambhawaami Studios' website promoted the film as an AI innovation, riding on Nandan's goodwill for views and revenue. The plaintiff highlighted the deceptive nature: the film's precision in replicating his likeness created false associations, diluting his unique identity and enabling fraud via fake profiles. He invoked the Copyright Act, 1957, for infringement of moral rights (Section 57), arguing that AI training on his images without consent breached his proprietary interest in his persona. Publicity rights were asserted as an extension of privacy, preventing unearned commercial gain from his fame.

Regarding platforms, Nandan urged strict compliance under the IT Rules, 2021, for expeditious takedown of infringing URLs and disclosure of user data, including IP addresses and BSI details, to trace perpetrators. He submitted evidence of over 40 infringing links (Annexure-A), including YouTube shorts with thousands of likes and Instagram reels fabricating family scenarios, like Nandan riding a motorcycle with uncle Chiranjeevi or romancing celebrities' daughters—none real.

Counsel for defendants D-2 (Google, represented by Aditya Gupta and Vani Kaushik) and D-3 (Meta, represented by Varun Pathak, Yash Karunakaran, and Prasidhi Agrawal) appeared but did not oppose, submitting compliance with any orders, including blocking sites and takedown notices. No substantive defense was presented at this stage, as the matter proceeded ex parte against D-1 and John Does. Deepak analogized to recent cases, warning of an "impending disaster" if AI misuse of personalities like Nandan's goes unchecked, potentially chilling free expression only if balanced against reputational harm.

Legal Analysis

The court's reasoning rooted in established precedents on personality rights, adapting them to AI's novel challenges. Central was the Delhi High Court's 2010 decision in DM Entertainment Pvt. Ltd. v. Baby Gift House & Ors. , where Justice S. Ravindra Bhat recognized the right of publicity as a common law extension of privacy and copyright, protecting against unauthorized commercial appropriation of one's persona. The judgment quoted extensively: "The right of publicity protects against the unauthorized appropriation of an individual’s very persona which would result in unearned commercial gain to another." It distinguished permissible expressions like parodies from exploitative uses, cautioning against chilling free speech but prioritizing harm to the individual's autonomy.

Justice Gedela applied this to AI deepfakes, observing that Nandan's "distinctive image and persona" made him identifiable, satisfying the identifiability threshold. The court noted the infancy of AI jurisprudence but relied on Ranganathan Madhavan v. G Filmz Studioz & Ors. (CS(COMM) 1392/2025, December 22, 2025), where a coordinate bench granted similar injunctions against AI films, reinforcing DM Entertainment 's principles. This precedent clarified that even non-celebrities with "noticeable presence" in entertainment qualify for protection, presuming Nandan's popularity from his fan following and film contributions.

The analysis invoked Article 21's privacy protections post- Justice K.S. Puttaswamy v. Union of India (2017), extending to digital manipulations that distort reputation. Under the Copyright Act, Section 57 safeguards moral rights against mutilation prejudicial to honor. The court distinguished deepfakes from benign AI uses, focusing on commercial intent: Sambhawaami's promotion evidenced exploitation for gain, unlike non-commercial parodies allowed under DM Entertainment . Platforms' intermediary liability under Section 79 IT Act and Rule 3(1)(b) of IT Rules, 2021, was invoked, mandating due diligence and 72-hour takedowns.

Gedela balanced equities: no prejudice to defendants from interim restraint, versus Nandan's irreparable loss—a "dent to the personality and image" unquantifiable in money. This aligns with Yamini Manohar v. T.K.D. Keerthi (2024) for exempting urgent IP suits from mediation. The ruling signals judicial evolution, treating AI as an amplifier of traditional IP threats, potentially influencing future cases on generative AI under emerging laws like the Digital Personal Data Protection Act, 2023.

Key Observations

The judgment extracts pivotal quotes underscoring the court's rationale:

1. "Upon overall appreciation of the facts of the case, prima facie, it appears that the plaintiff is a prominent personality belonging to a highly reputed family in the entertainment industry in the State of Andhra Pradesh. The plaintiff, though young, appears to have a large fan following which indicates his popularity in the public as also in the entertainment industry."

2. "The very act of deploying AI tools to create a movie with the plaintiff in the lead role, itself is a testament to his distinctive image and persona. It also appears that there is every likelihood of exploitation of his name, image, picture, personality, voice etc."

3. "The irreparable injury and loss that the plaintiff may suffer, if no restraint orders are passed, would be irreparable, in as much as, a dent to the personality and the very image of the plaintiff can neither be measured in monetary terms nor be resurrected conveniently."

4. From DM Entertainment (quoted): "No one is free to trade on another’s name or appearance and claim immunity because what he is using is similar to but not identical with the original."

5. "The images placed on record manifestly depict the vulnerability the plaintiff faces in the hands of purported infringers like defendant no.1... If that is so, the gravity and the seriousness with which this Court should approach such an infringer has to be underscored."

These observations highlight the prima facie case, balancing convenience, and the dangers of unchecked AI, integrating news details like fake donation scams to illustrate real-world harm.

Court's Decision

The Delhi High Court granted comprehensive ex parte ad-interim relief, restraining defendants, their agents, and John Does from:

• Creating, publishing, uploading, or disseminating AI Love Story or related content exploiting Nandan's persona via AI, deepfakes, or machine learning on any platform.

• Using his name ("Akira," "Akira Nandan," etc.), images, voice, mannerisms, or attributes for commercial or personal gain without consent.

• Violating privacy by distorting his image in prejudicial ways, including morphed content.

Specifically, Meta (D-3) was directed to notify users of infringing URLs (listed in Annexure-A, over 40 links) for takedown within 72 hours, failing which to remove content and disclose BSI/IP details within three weeks. Google (D-2) was to comply similarly. Sambhawaami Studios faced immediate takedown of its website content.

The order, under Order XXXIX CPC, lists the matter for February 5, 2026, with replies due in four weeks. Implications are profound: it affirms personality rights against AI threats, compelling platforms to act swiftly, potentially reducing deepfake virality. For legal practice, it bolsters IP strategies for public figures, encouraging early injunctions and data disclosure requests. Future cases may see expanded precedents, influencing AI regulations and deterring exploitative content creation, especially in entertainment where family legacies amplify risks. As news outlets noted, this protects not just celebrities but anyone with digital footprints from fraud and reputational sabotage, fostering a safer online ecosystem.