Celebrity Entitled To Safeguard His Interest Against Misuse Of Personality Attributes: Delhi High Court Grants Interim Injunction In Favour Of Karan Johar

The suit before the High Court was filed by the Plaintiff seeking permanent injunction restraining infringement of copyright, performer’s right, misappropriation of personality rights, publicity rights, passing off, tarnishment, damages and rendition of accounts.

The Single Bench of Justice Manmeet Pritam Singh Arora held, “Given the commercial value of these publicity rights, a celebrity is entitled to safeguard his interest against any misuse of the personality attributes which includes his name, image, voice and likeness. As noted above, the law has also recognized the right of the celebrity to seek injunction against unauthorized use of the personality rights. The Plaintiff has thus made out a prima facie case in his favour.”

Senior Advocate Rajshekhar Rao represented the Appellant, while Advocate Nirupam Lodha represented the Respondent.

Factual Background

The suit was filed by the Plaintiff, being aggrieved by the actions of an unknown entity i.e. John Doe as well as some known entities. The plaintiff, an acclaimed producer and director in the Indian film industry, claimed that the defendants are infringing his personality rights and/or providing a medium/platform. The petitioner claimed that these defendants are using AI to create morphed images (including deep fakes) and audio-video clips that are in poor taste and making the Plaintiff a subject of unwarranted and baseless humiliation, disparagement, obscenity and ridicule.

The plaintiff thus approached the High Court seeking an ad-interim injunction to protect and preserve its personality rights. As per the plaintiff, the Primary infringing defendants, without seeking the consent of the Plaintiff were engaged in various infringing activities qua the Plaintiff through various platforms, modes, and media. It was claimed that these activities were being undertaken either through the sale of merchandise using the personality rights of the Plaintiff or through unscrupulous use of AI by creating photos and audiovisuals which were in poor taste or by impersonation and cybersquatting. Thus, the plaintiff prayed for the grant of an ex parte ad-interim injunction in favour of the Plaintiff and against the Defendants.

Reasoning

On the basis of the assertions made in the plaint, the Bench noted that the Plaintiff is a well-known face and has a celebrity status. The Bench referred to the judgments where the personality rights of a celebrity have been recognised to include his/her right to protect against the unauthorised use of their personality, including their name, image, voice and other distinctive attributes.

On a prima facie assessment, the Bench found that the infringing websites and platforms had unauthorisedly exploited and misappropriated the Plaintiff’s voice, name and image for commercial gain, resulting in infringement of the Plaintiff’s personality rights; and thus, were liable to be enjoined. “On a prima facie view, it is evident that activities of the Defendant Nos. 8 to 13 mislead the general public to believe that the Plaintiff is either associated with the said Defendants or endorsing the products listed on the website of the said Defendants. And, use of Plaintiff’s personality attributes for sale of such products would also be in conflict with the Plaintiff’s existing endorsement deals”, it added.

The Bench also held that since the enlisted social media accounts on some of the platforms of the Defendants were unauthorizedly using the name of the Plaintiff, they were liable to be taken down in view of the objection raised by the Plaintiff. “The contention of the Plaintiff that the said accounts have the potential to mislead the public to believe that the said accounts are the official and/or authorized accounts of the plaintiff is prima facie plausible”, it mentioned.

Coming to the role of Meta, Google and Pinterest, the Bench stated, “On a prima facie assessment, it is evident that the videos, memes and social media posts available on the platforms of Defendant Nos. 7, 14 and 15 contains abusive and profane words as well as innuendoes, which appear to be offensive. The said content tarnishes the reputation and goodwill of the Plaintiff affecting his brand value. The Plaintiff is prima facie entitled to seek injunction to protect his personality rights again such negative use.” Considering that the Plaintiff had established a prima facie case for the grant of an ex parte ad interim injunction, the Bench held that the balance of convenience also lies in favour of the Plaintiff and against the Defendants. 

The Bench thus directed the defendants not to publish any material which infringes the personality rights of the Plaintiff and also asked that the domain names, URLs and disparaging content be taken down.

The Court also restrained the Primary Infringing Defendants or anyone acting for or on their behalf from utilizing the Plaintiff-Karan Johar’s name, his acronym ‘KJo’, likeness, image, voice, personality or any other aspects of his persona to create any merchandise, or in any other manner misuse the said attributes using technological tools which would result in violation of the Plaintiff's rights. The Bench has now listed the matter for February 19, 2026.

Cause Title: Karan Johar v. Ashok Kumar/John Doe & Ors. (Case No.: CS(COMM) 974/2025 & I.A. 22608/202)

Appearance

Appellant: Senior Advocate Rajshekhar Rao, Advocates Nizamuddin Pasha, Parag Khandhar, Chandrima Mitra, Krishan Kumar, Sidharth Kaushik

Respondent: Advocates Nirupam Lodha, Kshitiz Parashar, Gautam Wadhwa, Mamta Rani Jha, Rohan Ahuja, Shruttima Ehersa, Diya Viswanath, Aiswarya D., Devangini Rai, Varun Pathak, Yash Karunakaran

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