Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Online)(Del) 46955

IN THE HIGH COURT OF DELHI AT NEW DELHI
Manmeet Pritam Singh Arora, J
MKU LIMITED VS. SMPP PRIVATE LIMITED
CS(COMM) 1305/2025 | I.A. 30617/2025 | I.A. 30618/2025 | I.A. 30619/2025 | I.A. 30620/2025 | I.A. 32192/2025

Advocates:
For the Appellants/Petitioners: J. Sai Deepak, Alka Dahar, Shiv Verma, B. Sidhi Pramodh Rayudu, Purnima Vashishtha, Varun Sharma, Khushi Jain, Pankhudi Tripathi
For the Respondents: Manas Raghuvanshi, Mishthi Dubey, Shilpa Gupta, Surabhi Pande, Aditya Gupta, Vani Kaushik, Rohith, Varun Pathak, Amee Rana, Sana Banyal, Anannya Gogoi, Ankit Parhar, Abhishek Kumar, Shreya Gupta, Sanchli Sethi, Siddhartha Shankar Ray, Atishay Jain

Celebrity status grants an individual proprietary rights over their personality, name, image, and likeness, allowing them to seek injunctive relief against unauthorized commercial exploitation of these attributes by third parties.

Headnote:The case involves the Commercial Courts Act, 2015, the Copyright Act, 1957, the Trade Marks Act, 1999, and Articles 19 and 21 of the Constitution of India. The plaintiff, a renowned actor and cultural icon, sought a permanent injunction against the unauthorized commercial exploitation of his personality and publicity rights, specifically regarding the sale of infringing merchandise and the use of AI-generated content. The court found that the plaintiff's extensive professional achievements and brand value established a unique public association and celebrity status. The court addressed whether the plaintiff's name, image, and likeness are protectable elements of personality rights. Relying on established precedents, the court reasoned that celebrity status inherently grants proprietary rights over personality and associated attributes, and that unauthorized commercial use of these traits causes irreparable injury and economic loss to the individual. Defendant Nos. 1 [John Doe], 2 to 6, 11, 13, 14, 18, 20 and 21, their associates, servants, agents, affiliates, holding companies, assignees, substitutes, representatives, group entities, their subscribers, employees and/ or persons claiming through them or under them and all other persons are restrained from violating the Plaintiff’s personality rights by utilizing and/or in any manner directly and / or indirectly, using or exploiting or misappropriating the Plaintiff’s personality/ publicity rights by the use of the Plaintiff’s (a) name names ‘NANDAMURI TARAKA RAMA RAO JR.’, ‘NTR’, ‘JR. NTR’, ‘NTR JR.’, ‘MAN OF MASSES’, (b) styles, (c) photographs, and/or creating, sharing, disseminating, any product (including clothes, keychains, T-shirts, coffee mugs, posters, life-size cutouts), through the use of any technology including but not limited to printing, painting, artwork, Artificial Intelligence, Generative Artificial Intelligence, Machine Learning, Graphic Interchange Formats (GIFs) on any medium(s) and format(s), for any commercial gain by exploiting them in any manner whatsoever without the Plaintiff’s consent and/or authorization.

Table of Content
1. disposal of preliminary interlocutory applications regarding mediation, documents, and statutory notices. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12)
2. registration of the commercial suit and issuance of summons to infringing defendants. (Para 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22)
3. assertion of personality and publicity rights based on celebrity status and trademark registrations. (Para 23 , 24)
4. recognition of celebrity status as a basis for proprietary personality rights. (Para 25 , 26 , 27 , 28 , 29 , 30 , 31)
5. grant of ex-parte ad-interim injunction and directions to intermediaries and e-commerce platforms. (Para 32 , 33 , 34 , 35 , 36 , 37 , 38 , 39 , 40 , 41 , 42 , 43 , 44 , 45)

O R D E R

I.A. 30618/2025

(seeking exemption from pre-litigation mediation)

1. This is an application filed by the Plaintiff under Section 12A of the Commercial Courts Act, 2015 read with Section 151 Code of Civil Procedure, 1908 [‘CPC’], seeking exemption from instituting pre-litigation mediation.

2. Having regard to the facts that the present suit contemplates urgent interim relief and in light of the judgement of the Supreme Court in Yamini Manohar v. T.K.D. Keerthi , (2024) 5 SCC 815, exemption from the requirement of pre-institution mediation is granted to the Plaintiff.

3. Accordingly, the application stands disposed of.

I.A. 32192/2025

(seeking leave to file additional documents)

4. This is an application filed by the Plaintiff under Order XI Rule 1(4) of CPC [as amended by the Commercial Courts Act, 2015], seeking leave to file additional documents annexed to this application as document nos. 34 to 63.

5. For the reasons stated in the application and considering that the suit is still at the stage of issuance of summons, the prayer is allowed and the documents are taken on record.

6. Accordingly, the application is disposed of.

I.A. 30620/2025

(seeking permission for filing lengthy submissions)

7. This is an application filed under Section 151 of CPC seeking permission for filing lengthy list of dates and synopsis.

8. For the reasons stated in the application, the application is allowed.

9. Accordingly, the applications stand disposed of.

I.A. 30619/2025

(seeking exemption from Section 80 CPC)

10. This is an application filed under Section 151 of CPC seeking exemption from serving two (2) months’ statutory notice upon Defendant Nos. 27 and 28 under Section 80 of CPC.

11. For the reasons stated in the application and considering the fact that defendant no. 27 and 28 are proforma defendants, exemption is allowed.

12. The application stands disposed of.

13. The present suit has been filed seeking a permanent injunction inter alia against misappropriation of the personality and publicity rights of the plaintiff, infringement of copyright and other reliefs.

14. The plaint be registered as a suit.

15. Issue summons to the Defendants Nos. 2 to 6, 11, 13, 14, 18, 20 and 21 (‘infringing defendants’) who are unauthorisedly selling merchandize by all permissible modes on filing of process fee. Affidavit of service be filed within four (4) weeks.

16. The Defendants will file the written statement(s) within thirty (30) days. The Defendants shall also file affidavit(s) of admission/denial of the documents filed by the Plaintiff, failing which the written statement(s) shall not be taken on record.

17. The Plaintiff is at liberty to file replication thereto within thirty (30) days after filing the written statement(s). The replication shall be accompanied by affidavit of admission/denial in respect of the documents filed by Defendants, failing which the replication shall not be taken on record.

18. It is made clear that any unjustified denial of documents may lead to an order of costs against the concerned party.

19. Any party seeking inspection of documents may do so in accordance with the Delhi High Court (Original Side) Rules, 2018.

20. No summons are being issued to Defendant Nos. 12, 15, 16, 17, 23, 24, 25, 2

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2025 Supreme(Online)(Del) 46955

IN THE HIGH COURT OF DELHI AT NEW DELHIManmeet Pritam Singh Arora, JMKU LIMITED VS. SMPP PRIVATE LIMITEDCS(COMM) 1305/2025 | I.A. 30617/2025 | I.A. 30618/2025 | I.A. 30619/2025 | I.A. 30620/2025 | I.A. 32192/2025

Celebrity status grants an individual proprietary rights over their personality, name, image, and likeness, allowing them to seek injunctive relief against unauthorized commercial exploitation of these attributes by third parties.

Cases Referred (1)

IN THE HIGH COURT OF DELHI AT NEW DELHI
Manmeet Pritam Singh Arora, J
MKU LIMITED VS. SMPP PRIVATE LIMITED
CS(COMM) 1305/2025 | I.A. 30617/2025 | I.A. 30618/2025 | I.A. 30619/2025 | I.A. 30620/2025 | I.A. 32192/2025