Court Holds Unauthorized Use of Name, Image, Voice and Likeness for Merchandise and AI Content Violates Personality Rights
Shivaji Rathore 02-01-2026
The Delhi High Court has passed an ex-parte ad-interim John Doe injunction protecting the personality and publicity rights of Pawan Kalyan, the Deputy Chief Minister of Andhra Pradesh, against unauthorised commercial exploitation of his name, image, voice and likeness. Justice Manmeet Pritam Singh Arora held that the defendants were prima facie using the plaintiff’s attributes for commercial gain, including sale of merchandise and AI-generated content, without his consent, either directly or through various e-commerce and social media platforms.
Unauthorized Commercial Use Amounts to Violation of Personality Rights :- The Court observed that the unauthorised use of Pawan Kalyan’s name, photographs, likeness, voice and persona by the infringing defendants amounted to a prima facie violation of his personality rights. It noted that the plaintiff enjoys significant commercial goodwill and brand value on account of his long-standing career in cinema and public life, and that such goodwill cannot be misappropriated for profit without authorisation.
Holding that the balance of convenience lay in favour of the plaintiff, the Court further observed that continued availability of the infringing content would cause irreparable injury to his rights and reputation.
“The Plaintiff has therefore, made out a case for ex-parte ad-interim injunction against the infringing Defendants,” the Court held.
Directions to E-Commerce, Social Media and AI Platforms:- The Court restrained the John Doe defendants and identified infringing parties from using or exploiting Pawan Kalyan’s personality attributes for any commercial purpose, including through artificial intelligence, deepfakes, digital editing or online platforms. E-commerce platforms were directed to take down infringing listings, delist unauthorised merchandise and furnish KYC details of infringers. AI-based platforms facilitating generation of synthetic voice, images or content using the plaintiff’s identity were also restrained from continuing such services. The Court clarified that if any website or party, not primarily an infringer, is affected due to the operation of the order, it may approach the Court by giving an undertaking that it does not intend to disseminate infringing content, whereupon the Court may consider modification of the injunction.
Intermediary Guidelines and IT Rules :- The Court noted that it had earlier directed social media and e-commerce platforms to treat the plaintiff’s suit as a complaint under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, requiring timely action against infringing content.
Part of a Growing Line of Personality Rights Protection:- Justice Arora has recently passed similar John Doe orders protecting the personality rights of several public figures, including former cricketer Sunil Gavaskar, actors R. Madhavan and NTR Junior, journalist Sudhir Chaudhary, and podcaster Raj Shamani. Coordinate benches of the Delhi High Court have also granted personality rights protection to Sri Sri Ravi Shankar, Nagarjuna, Aishwarya Rai Bachchan, Abhishek Bachchan, and filmmaker Karan Johar.
A similar personality rights suit has also been filed by actor Salman Khan.
Case Details
Case Title: Mr. Konidala Pawan Kalyan v. Ashok Kumar (John Doe) & Ors.
Case No.: CS(COMM) 1336/2025
Court: Delhi High Court
Judge: Justice Manmeet Pritam Singh Arora
Date of Order: 22 December 2025
Counsels
For the Plaintiff:
Senior Advocate J. Sai Deepak with Mr. Himanshu Deora, Mr. Rahul Mehta, Mr. Arpit Choudhary, Mr. Krumal Mehta, Ms. Anupriya Alok, Ms. Shambhavi Sharma, Mr. Sanat, Ms. Shambhavi Bhardwaj, Ms. Karen Koya and Ms. Dhwani Vora, Advocates.
For the Defendants:
Ms. Shilpa Gupta and Ms. Surabhi Pande, Advocates (D-2);
Ms. Srishti Dhoundiyal, Advocate (D-3);
Ms. Mishthi Dubey, Advocate (D-4);
Mr. Aditya Gupta, Ms. Vani Kaushik and Mr. Rohith Venkatesan, Advocates (D-5);
Mr. Varun Pathak, Mr. Yash Karunakaran and Ms. Varsha Jhavar, Advocates (D-6).
