Delhi High Court Landmark Judgment Safeguards Hrithik Roshan’s Personality Rights Against AI Misuse, Deepfakes, and Unauthorized Exploitation
It is entirely in the fitness of things and absolutely pragmatic that the Delhi High Court in a most learned, laudable, landmark, logical and latest judgment titled Hrithik Roshan vs Ashok Kumar/John Doe & Ors in CS(COMM) 1107/2025 & I.A. 25665-25667/2025 that was pronounced as recently as on 15.10.2025 has granted protection to personality rights to film actor Hrithik Roshan. It must be noted that the Single Judge Bench comprising of Hon’ble Ms Justice Manmeet Pritam Singh Arora restrained John Doe defendants (unknown entities) from utilizing Hrithik Roshan’s name, likeness, image, voice, personality or any other aspects of his persona to create any merchandise, misuse using Artificial Intelligence, deep fakes, machine learning, face morphing or GIFs for commercial purpose.
It is also worth paying attention that the Bench observed that the actor’s attributes are protectable elements of his personality rights against impersonation, false, obscene, morphed and distorted content. It also must be noted that while citing its past observations made in similar cases pertaining to the personality rights of Bollywood film personalities, Anil Kapoor, Karan Johar and Jackie Shroff, the Delhi High Court made it indubitably clear that unauthorized exploitation of their personality rights for commercial gain can be protected by way of injunction. It was also held by the Bench that the interim order would remain valid till March 27, 2026 when the matter is slated to be heard next.
At the very outset, this brief, brilliant, bold and balanced judgment authored by the Single Judge Bench comprising of Hon’ble Ms Justice Manmeet Pritam Singh Arora of Delhi High Court sets the ball in motion by first and foremost putting forth in para 1 that:
This is an application filed under Section 12A of the Commercial Courts Act, 2015 read with Section 151 Code of Civil Procedure, 1908 (‘CPC’), filed by the Plaintiff seeking exemption from instituting pre-litigation mediation.”
As we see, the Bench then stating the purpose of the application lays bare in para 2 disclosing that:
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. Moreover, in this case reliefs are also sought against unknown entities impleaded as Defendant No. 1/John Doe and no pre-suit mediation is possible with these entities.”
While continuing in the same vein, the Bench reveals in para 7 observing that, “The present suit has been filed seeking permanent injunction restraining the Defendants from misappropriation of personality rights, publicity rights, infringement of copyright, performer’s rights and passing off, along with other ancillary relief.”
To put things in perspective, the Bench envisages in para 21 stating that:
Mr. Sandeep Sethi, learned senior counsel for the Plaintiff sets the Plaintiff’s case as under:
21.1 The Plaintiff, Mr. Hrithik Roshan, born in Mumbai to renowned filmmaker Rakesh Roshan, began his acting career as a child artist. He made his debut as a lead actor in ‘Kaho Naa Pyaar Hai’, which became a blockbuster success and earned him multiple prestigious awards including the Filmfare Awards for Best Actor and Best Male Debut.
21.2 The Plaintiff received widespread recognition for his portrayal in ‘Koi Mil Gaya’. The film’s fictional character ‘Jadoo’ also became widely associated with him. Following this success, he starred in several acclaimed films such as ‘Krrish, Fiza, Mission Kashmir, Yaadein, and Super 30’, showcasing his versatility as an actor and dancer, and establishing himself as a leading figure in contemporary Indian cinema.
21.3 The Plaintiff is a successful actor, having acted in over 25 films. Additionally, the Plaintiff has endorsed many national and international brands, significantly enhancing their market presence through his association. The Plaintiff is a shareholder in XS Brands Consultancy Pvt. Ltd., which owns the activewear and fitness brand ‘HRX’, named after the Plaintiff. HRX is associated with the Plaintiff’s initials and personal values of health and fitness, contributing to the brand’s rapid growth in India.
21.4 The Plaintiff is also a director at Filmkraft Productions (India) Pvt. Ltd., a leading production house responsible for several well-known films. The Plaintiff in his career has already received multiple prestigious awards, including the National Citizen’s Award, 6 Filmfare Awards, 8 IIFA Awards, 7 Zee Cine Awards, and 5 Screen Awards.
21.5 The Plaintiff has a long and respected career in cinema, gaining admiration from audiences in India and worldwide. The Plaintiff has created an invaluable asset for himself in the form of the love and admiration he has with the millions of fans in India and abroad. He has a significant social media presence on social media platforms, with 48M followers on Instagram, 32.2M on X, and 48.1M on Facebook, and these numbers are growing each day. He has represented well-known brands like Zebronics, Mountain Dew, and Gillette as their brand ambassador.
Defendants’ Infringing Actions
21.6 Defendant Nos. 1, along with infringing Defendants are unlawfully using the Plaintiff’s personality traits for commercial gain, by infringing on his publicity rights and damaging his reputation by creating vulgar and obscene content with the use of Artificial Intelligence [‘AI’].
21.6.1 Defendant Nos. 3 to 7 are Domain Name Registrants [‘DNRs’] and there are domain names registered with these DNRs which have hosted infringing material which violates the Plaintiffs personality rights. Defendant nos. 13 to 28 and Defendant Nos. 29 to 33 are e-platforms used by the infringing Defendants for this misuse and have been impleaded for compliance purposes.
21.6.2 Defendant No. 1 is Ashok Kumar/John Doe, representing the unidentified person/unknown entities who are violating the Plaintiff's personality rights and publicity rights.
21.6.3 Defendant No. 2/Jammable Limited operates a website that enables its users to create audio clips, through Artificial Intelligence, in the Plaintiff’s voice.
21.6.4 Defendant Nos. 3 to 7 are Domain Name Registrants [‘DNRs’], wherein domain names have been registered, which host websites against which the Plaintiff has raised a grievance. It is stated that these websites allow its users to create morphed images, memes, Artificial Intelligence generated content including text/images/audio clips, that exploit Plaintiff’s image, personality, voice and other attributes.
21.6.5 Defendant Nos. 8 to 10 own and operate websites, which are offering mobile applications. These applications misuse Plaintiff’s image/voice/name and other personality attributes, without his authorization and thus to violate personality rights.
21.6.6 Defendant No. 11 is a webpage wrongfully projecting to the public at large that Plaintiff is the founder of Defendant No. 4/Markmonitor.Inc.
21.6.7 Defendant No. 12/GIPHY is an online database to search and share images/GIFs and this database permits exploitation of the Plaintiff’s image/likeness/name and other personality attributes.
21.6.8 Defendant Nos. 13 to 28 are various online e-marketplaces/ecommerce websites used by third-parties to sell the products/merchandise unauthorizedly using various personality attributes of the Plaintiff and making monetary benefit out of it.
21.7 It is stated that infringing Defendants are misusing the Plaintiff’s name, images, and attributes, including morphed and AI-generated content, to deceive his fans for illegal profits, violating his personality and publicity rights. The Plaintiff asserts that no one can use his personality rights without his consent. It is stated that some of the content is also vulgar and demeans the Plaintiff.”
Be it noted, the Bench notes in para 32 that:
In the present suit, the Plaintiff has joined multiple causes of action arising from the unauthorized use of his personality rights by third parties, including the sale of merchandise for commercial gain, publication and circulation of disparaging and obscene memes, impersonation, and unauthorized use of the Plaintiff’s attributes such as voice/name/face through morphing, superimposition, artificial intelligence, and creation of GIFs. The Plaintiff has asserted that such unauthorized acts constitute violation of his statutory and common law rights under the Copyright Act, 1957, the Trade Marks Act, 1999 and further amount to infringement of his right to privacy, goodwill, and reputation.”
It is worth noting that the Bench notes in para 33 that:
The assertions made in the plaint and submissions made by the learned senior counsel for the Plaintiff, leave no doubt that the Plaintiff is a well-known face in India who has gained immense goodwill and reputation over a course of a very successful career and has acquired a celebrity status in India.”
It would be instructive to note that the Bench hastens to add in para 34 noting that:
The law, as laid down in D.M. Entertainment v. Baby Gift Others, House MANU/DE/2043/2010, Anil Kapoor v. Simply Life India and Others 2023 SCC OnLine Del 6914 [Paragraph Nos. 38 to 40], and Jaikishan Kakubhai Saraf Alias Jackie Shroff v. The Peppy Store and Others 2024 SCC OnLine Del 3664 recognizes that an individual’s right to control the commercial use of his likeness and personality attributes forms part of the right of publicity. The Courts have consistently held that the unauthorized use of a person’s name, image, voice, or other distinctive attributes for commercial purposes constitutes an infringement of such right, amounting to dilution of the individual’s unique identity and leading to unearned commercial gain by others. It is well settled that where such personality rights are established, the individual is entitled to protection by way of injunction against their unauthorized use or exploitation.”
Most significantly, the Bench encapsulates in para 37 what constitutes the cornerstone of this notable judgment postulating precisely that:
Accordingly, until the next date of hearing, following directions are hereby issued with respect to each Defendant and with specific reference to Annexure A, enclosed with this order: -
37.1 Defendant Nos. 1/John Doe, and infringing Defendants i.e., Defendant Nos. 2, and 8 to 12 or any one acting for or on their behalf are restrained from utilizing the Plaintiff – Hrithik Roshan’s; name, 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 such as Artificial Intelligence, deep fakes, machine learning, face morphing, GIFs either for monetary gains or otherwise to create any videos, photographs, etc., for commercial purposes, so as to result in violation of the Plaintiff’s personality rights and publicity rights.
37.2 Defendant Nos. 2 is restrained from publishing any material which infringes the personality rights of the Plaintiff and is directed to take down the URL enlisted in Annexure A.
37.3 Defendant Nos. 3 to 7 are directed to suspend and lock the impugned domain names on which the websites enlisted in Annexure A are posted, and also, provide the complete details of the registrant of the said domains name including the IP addresses.
37.3.1 The registrants of the said websites are granted liberty to approach this Court and give an undertaking that they will abide by the injunction granted against the infringing Defendants and not infringe the personality rights and publicity rights of the Plaintiff; and thereafter appropriate directions will be issued for unblocking the concerned domain name.
37.4 Defendant No. 8, 9 and 10 are directed to take down and block access to the mobile applications enlisted in Annexure A.
37.5 Defendant No. 11 is directed to take down the infringing URL enlisted in Annexure A.
37.6 Defendant no. 12 is directed to take down the infringing URLs enlisted in Annexure A.
37.7 Defendant Nos. 13 and 28 are directed to take down and delist the infringing links enlisted in Annexure A.
37.8 Defendant Nos. 29 and 30 are directed to take down the infringing links enlisted in Annexure A.
37.9 Defendant Nos. 31 is directed to take down the infringing URLs, enlisted in Annexure A. However, the URL corresponding to page 139 and 140 of the paper books will not be taken down.
37.10 Defendant No. 32 is directed to take down the infringing URLs, enlisted in Annexure A.
However, the URLs corresponding to social media profiles filed as document no. 26 of the paper-book will not be taken down.
So also, with respect to document no. 31, URLs only for the specific posts at pages 118, 119 and 121 are directed to be taken down by Defendant No. 32. There is no direction to take down this profile. However, if any other disparaging post is uploaded on this profile, Plaintiff will be at liberty to approach Defendant No. 32 for take down of such a post.
37.11 Defendant no. 33 is directed to take down the infringing link corresponding to document no. 39 in the paper-book, also enlisted at Annexure A.”
It would be worthwhile to note that the Bench notes in para 43 that:
The Defendants will comply with these directions within 72 hours from the receipt of this order.”
Further, the Bench directs in para 44 that:
Compliance with Order XXXIX Rule 3 of CPC be done within 10 days from today.”
Furthermore, the Bench then directs in para 48 that:
List before the learned Joint Registrar (J) on 04.12.2025.”
What’s more, the Bench further directs in para 49 that:
List before Court on 27.03.2026.”
Finally, the Bench then concludes by holding and directing in para 50 that:
The digitally signed copy of this order, duly uploaded on the official website of the Delhi High Court, www.delhihighcourt.nic.in, shall be treated as a certified copy of the order for the purpose of ensuring compliance. No physical copy of order shall be insisted by any authority/entity or litigant.”
Sanjeev Sirohi, Advocate,
s/o Col (Retd) BPS Sirohi, A 82, Defence Enclave,
Sardhana Road, Kankerkhera, Meerut - 250001, Uttar Pradesh.
