P.C:

1 By the present Suit, the Plaintiff has inter-alia sought the protection of his personality rights, his right to privacy and right to live with dignity guaranteed under Article 21 of the Constitution of India and also the protection of his moral rights under the Copyright Act, 1957. The Plaintiff asserts that his stated rights are being infringed and violated by unauthorized use and commercial exploitation and misrepresentation on different social media platforms and over the internet by various parties some of whom are arrayed as Defendants to the suit and by certain unknown entities presently found as Ashok Kumar / Jon Doe.

2 The Plaintiff has in the plaint set out that the Plaintiff is a renowned Indian film actor, producer and public figure with a career in the Indian film industry spanning over three decades. In Paragraph No. 21 of the plaint, the Plaintiff has given a list of nearly 100 films in which he has acted and is widely known for his performances in commercially successful and critically acclaimed films such as “Balwaan”, “Mohra”, “Dilwale”, and “Border”, Main Hoon Na and the film “Hera Pheri” in which the Plaintiff played the iconic and popular character of “Shya