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2026 Supreme(Online)(Del) 13809
IN THE HIGH COURT OF DELHI AT NEW DELHI
Jyoti Singh, J
Ravindra Shukla – Appellant
Versus
Ashok Kumar – Respondent
CS(COMM) 680/2026
For the Appellants/Petitioners: N. Hariharan, Sanjay Upadhyay, Krishna Kumar Shukla, Neeraj Grover, Madhav Anand, Alvin Antony, Pranav Prasoon, Mansi Bachani, Kaulik Mitra, Kunal Khanna, Surya Pratap Singh, Jitendra Bohra
For the Respondents: Amee Rana, Radhika Roy, Vishwajeet Deshmukh, Rohan Ahuja, Shruttima Ehersa, Ankit Tripathi
Personality rights, including an individual's name, likeness, and image, are legally protected, and unauthorized commercial exploitation or use in obscene content infringing upon these attributes warrants injunctive relief to protect an individual's reputation, privacy, and dignity.
Headnote:(A) Trade Marks Act, 1999 - Copyright Act, 1957 - Personality/Publicity Rights - Unauthorized use of personality attributes - Plaintiff seeking permanent and ad interim injunction against defendants - Defendants using plaintiff's name, image, and persona for pornographic content and unauthorized commercial exploitation - Court finds prima facie case for infringement and disparagement - Injunction granted against misappropriation using AI and other technologies. (Paras 32, 33, 36, 39)
Facts of the case:
Plaintiff is a well-known actor and politician who claims that his name, voice, image, and catchphrases possess significant commercial value and personality rights. He alleged that several defendants were misusing these attributes to create vulgar, obscene, and pornographic content, and further creating deepfakes to damage his reputation and goodwill. Plaintiff sought an ad interim injunction to restrain such unauthorized activities.
Findings of Court:
The Court held that personality rights are legally protected assets. The unauthorized use of a famous person's attributes not only leads to commercial loss but also interferes with the right to live with dignity and privacy. The Court found a balance of convenience in favor of the plaintiff and restrained the defendants from exploiting his personality rights.
Issues: Whether the plaintiff's personality/publicity rights are violated by the defendants' act of creating/hosting pornographic or unauthorized content using his name and likeness.
Ratio Decidendi: Personality rights are judicially recognized and require protection. Unauthorized use of a celebrity's persona for commercial or obscene purposes warrants immediate injunctive relief to prevent irreparable harm to the person's reputation and dignity.
Result: Application for ad interim injunction allowed.
| Table of Content |
|---|
| 1. procedural rulings on summons, notices, and exemption of pre-institution mediation requirements. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27) |
| 2. basis of the plaintiff's claim regarding personality/publicity rights protection. (Para 28 , 29 , 30 , 31 , 32 , 33) |
| 3. counsel's arguments regarding unauthorized commercial exploitation of celebrity persona. (Para 34 , 35) |
| 4. court's judicial recognition of personality rights and need for protection against infringement. (Para 36 , 37 , 38) |
| 5. final order granting ad interim injunction and procedural directions for compliance. (Para 39 , 40) |
I.A.16470/2026 (Exemption)
1. Allowed, subject to all just exceptions.
2. Application stands disposed of.
I.A. 16468/2026 (u/O XI Rules 1, 2, 3 and 5 CPC r/w Chapter IV of the Delhi High Court (Original Side) Rules, 2018 and Section 151 CPC)
3. This application is filed on behalf of Plaintiff seeking discovery by interrogatories and production of documents along with supporting affidavit.
4. Issue notice.
5. Ms. Amee Rana and Mr. Rohan Ahuja, learned counsels accept notice on behalf of Defendants No. 30 and 31 respectively.
6. Issue notice to the remaining Defendants through all permissible modes, returnable before the learned Joint Registrar on 13.08.2026.
I.A. 16469/2026 (u/O XI Rule 1(4) of Commercial Courts Act, 2015 r/w Section 151 CPC)
7. This application is filed on behalf of the Plaintiff seeking time to file additional documents.
8. Plaintiff, if he wishes to file additional documents at a later stage, shall do so strictly in accordance with the provisions of the Commercial Courts Act, 2015.
9. Application is allowed and disposed of.
I.A 16471/2026 (for pre-institution mediation)
10. This application is filed on behalf of the Plaintiff under Section12-A of the Commercial Courts Act read with Section 151 CPC, seeking exemption from Pre-Institution Mediation.
11. Having regard to the facts of the present case wherein urgent relief is prayed for and in light of the judgment of Supreme Court in Yamini Manohar v. T.K.D. Keerthi , (2024) 5 SCC 815, as also Division Bench of this Court in Chandra Kishore Chaurasia v. RA Perfumery Works Private Ltd. , 2022 SCC OnLine Del 3529, exemption is granted to the Plaintiff from Pre-Institution Mediation.
12. Application is allowed and disposed of.
I.A. 16472/2026(u/S 151 CPC)
13. This application is filed on behalf of the Plaintiff seeking leave to file certain documents in a compact disk/pen drive.
14. For the reasons stated in the application, the same is allowed, permitting Plaintiff to file documents in a compact disk/pen drive.
15. Application stands disposed of.
16. Let plaint be registered as a suit.
17. Issue summons.
18. Ms. Amee Rana and Mr. Rohan Ahuja, learned counsels accept summons on behalf of Defendants No. 30 and 31, respectively.
19. Upon filing of process fee, issue summons to the remaining Defendants through all permissible modes, returnable before the learned Joint Registrar on 13.08.2026.
20. Summons shall state that the written statements shall be filed by the remaining Defendants within 30 days from the receipt of summons along with affidavits of admission/denial of the documents filed by the Plaintiff.
21. It will be open to the Plaintiff to file replications within 30 days from the date of receipt of written statements along with affidavits of admission/denial of documents filed by the remaining Defendants.
22. If any of the parties wish to seek inspection of any documents, the same be sought and given the timeline prescribed in Delhi High Court (Original Side) Rules, 2018.
23. Learned Joint Registrar will carry out admission/denial of documents and marking of exhibits
I.A. 16467/2026(u/O XXXIX Rules 1 and 2 r/w Section 151 CPC)
24. This application is filed on behalf of the Plaintiff under Order XXXIX Rules 1 and 2 read with Section 151 of CPC for grant of ex parte ad interim i
