In a significant development for the protection of personality and publicity rights in the Indian entertainment industry, the Delhi High Court has issued a stern directive against the makers of the film Doosra . Presiding over the dispute, Justice Tejas Karia ruled that the movie engaged in the unauthorized exploitation of former Indian cricket captain Sourav Ganguly’s public persona. To mitigate the ongoing impact of this infringement, the Court has mandated that the producers, Ramesh Deo Productions Private Limited, must now implement specific disclosure measures and provide substantial financial security to the Court, effectively balancing the right of creators to depict public life with the inherent rights of celebrities to control their own likeness for commercial purposes.

The legal action was initiated by Sourav Ganguly in collaboration with Luv Films LLP, a production company that holds exclusive contractual rights for a legitimate, authorized biopic based on the cricketer’s life. The plaintiffs argued that Doosra encroached upon these rights by featuring iconic moments from Ganguly’s professional and personal journey—most notably his captaincy during the historic NatWest cricket series final and his celebrated shirtless gesture at the Lord’s balcony—without his consent. The litigation highlights the escalating friction between filmmakers documenting public events and the legal entitlements of the individuals whose careers define those events.

The court’s order is comprehensive, focusing on immediate damage control to ensure audiences are not misled regarding the nature of the production. Justice Karia emphasized the complexity of separating the cricketer’s identity from the narrative structure of the film, noting that "Ganguly's personality and publicity rights are so intertwined with the story of the film that it will not be feasible for those parts to be removed from the film." Because a total excision of the infringing scenes would render the production unviable, the court opted for a mandatory disclosure regime .

Under the current directives, Ramesh Deo Productions must include a prominent disclaimer in both Hindi and English. This notice must clearly state that Sourav Ganguly did not provide consent for the utilization of his persona and that the film is not intended to violate his personality and publicity rights. The court has granted the producers a narrow window of two days to ensure these disclaimers are integrated at both the beginning and the end of the motion picture.

Beyond the requirement for transparency, the Court has imposed a significant financial condition to ensure the protection of the plaintiff’s interests. The makers of Doosra are now required to furnish an unconditional bank guarantee amounting to ₹2 crore with the Court’s registrar. The deadline for this deposit has been set for two weeks from the date of the order. This measure serves as a form of security against potential damages that may arise from the alleged unauthorized commercialization of Ganguly’s brand. The Court also clarified the consequences of non-compliance, stating that if the defendants fail to meet either the disclaimer or the financial guarantee requirements, they—and any entities acting on their behalf—will be restrained from any further commercial use of the film or any of its constituent elements.

The dispute underscores a broader trend in Indian jurisprudence regarding the commodification of celebrity identities. As public figures gain more agency over their personal histories, the legal threshold for "unauthorized exploitation" has become a central point of contention for production houses. While historical events are often considered part of the public domain, the court’s decision suggests that the deliberate framing of a person’s likeness in a commercial medium, particularly when that likeness is tied to exclusive commercial contracts held by other parties, warrants judicial scrutiny.

For Luv Films LLP, the legal victory is essential to preserving the value of their forthcoming, authorized biopic project. By seeking an injunction against the theatrical, digital, and promotional release of Doosra , the plaintiffs effectively sought to prevent market confusion and the dilution of the brand value associated with Ganguly’s career. The defendants had reportedly been using the cricketer’s name, image, and specific iconic moments to draw public interest, which the court has now determined to be an overreach.

The procedural history of this case reveals that the underlying agreement between Ganguly and Luv Films, which was formalized on August 5, 2021, granted the production house the sole rights to depict his life. By contrast, the unauthorized nature of the biographical elements featured in Doosra undermined the exclusivity of this agreement. The Court’s decision to mandate a ₹2 crore guarantee acts as a financial buffer, acknowledging the potential revenue loss and reputational strain caused by the film’s release.

This case serves as a warning to filmmakers who rely on the depiction of public figures without securing the necessary permissions or rights. The Court’s approach—refusing to order a total ban while simultaneously imposing strict operational and financial conditions—is a pragmatic attempt to mediate between the competing interests of artistic expression and the legal rights of individuals. The industry is now closely watching how these compliance mandates are fulfilled. With the two-day deadline for the disclaimer and the two-week deadline for the financial guarantee approaching, the immediate future of the film’s commercial viability remains contingent upon the defendants' ability to adhere strictly to the Court’s instructions. Should the producers fail to comply, the judiciary stands ready to enforce a total freeze on the movie’s distribution, a move that would represent a significant setback for the production team.

The case continues to move through the judicial process, and the fulfillment of these court-mandated conditions will be the next critical milestone. The legal community is expected to scrutinize the implementation of these directives as a benchmark for how similar disputes involving personality rights will be handled in the future. As it stands, the ball is firmly in the court of the filmmakers to demonstrate their compliance with these judicial expectations.