The Delhi High Court on October 29, 2026, passed an interim order protecting actor Kriti Sanon’s personality rights against the unauthorised use of her name, image, likeness and voice, including AI-generated sexual deepfakes, impersonation and synthetic voice models. Justice Purushaindra Kumar Kaurav, hearing the commercial suit filed by Sanon against BBE Marketing Inc and others, restrained specified defendants from uploading, hosting, generating or making available such content.

The Court also directed online intermediaries to take down identified URLs and ordered the blocking of websites hosting pornographic deepfakes. However, the Court clarified that it would decide the questions concerning personality rights on their merits after hearing the contesting defendants. The interim arrangement will remain in place until the next hearing.

What does the interim order restrain?

  • BBE Marketing: The Court restrained it from uploading, hosting, generating, or making available material falsely representing an association with Sanon. The plaint alleged that it was offering bookings for her appearances.
  • Impersonation accounts: The order covers accounts on YouTube, Facebook, X, and Pinterest that held themselves out as Sanon’s official presence or circulated AI-generated, morphed, or sexually suggestive images.
  • Merchandise seller: The injunction covers merchandise using her image, including products allegedly using images from Sanon’s personal life.
  • AI chatbots, synthetic voice models and image generation: Four defendants were restrained from making available chatbots or voice models presented as Sanon, as well as further material generated using her identity.
  • Pornographic deepfake websites: Government authorities were directed to issue blocking directions for pornographic websites containing AI-generated deepfakes of Sanon.
  • Intermediaries: They were directed to take down or restrict access to URLs. The order noted that defendant No. 3, Google, was the only party to respond to Sanon’s communication in August, directing her to its reporting tool.

The Court clarified that the order does not restrain news, reviews, criticism, commentary, satire, parody, caricature or fan expression that does not fall within the prohibited categories.

Observations on personality rights: The Court observed that “Personality rights” is not a single cause of action but a term describing distinct legal claims, including publicity rights, privacy, passing off, defamation and, where applicable, statutory intellectual property rights. It noted that “No statute creates any such right” as a single personality right, and said the Court must first identify the right alleged to have been infringed.

Distinguishing privacy from publicity rights, the Court said that privacy, dignity and reputation are personal interests that “cannot be assigned and they end with the person”. In contrast, publicity rights protect the commercial value of identity and “can be licensed”. It added that the right of publicity “is, therefore, not the same as the right of privacy, though it has roots in it”. The Court also said passing off requires “a misrepresentation as to endorsement or association”.

Referring to Titan Industries v. Ramkumar Jewellers, the Court discussed publicity rights as a commercial right over human identity. It also cited Digital Collectibles Pte. Ltd. v. Galactus Funware Technology Pvt. Ltd. on the limits of publicity rights and the protection available to satire, parody, art, scholarship and news under Article 19(1)(a).

The Court held that “Placing them all under one label cannot lower the threshold that applies to any one of them”. It further said that the rights “are available to every individual”, and fame is not a condition for their existence. However, “the mere use of a person’s identity is not, by itself, unlawful”.

The Court said plaintiffs must identify the claim and supporting material “defendant-wise and content-wise”, with corresponding specific relief. It also described intermediaries as “parties for compliance, not wrongdoers”, requiring removal directions to identify the material concerned.

What Gautam Bhatia suggested: The Delhi High Court appointed lawyer Gautam Bhatia as amicus curiae, or a court-appointed adviser, in actor Janhvi Kapoor’s personality rights suit. The Court is examining the scope of personality rights under Indian law while hearing the suits involving Janhvi Kapoor, Vivek Oberoi and Aaradhya Bachchan.

Bhatia argued that personality rights are not a single cause of action. Plaintiffs should identify each legal interest, the alleged harm, remedy sought, and countervailing rights, including free speech. Accordingly, courts should reject sweeping John Doe injunctions where claims remain undifferentiated.

He urged the Court not to treat a person’s image as property beyond statutory copyright and trademark protections. Instead, commercial misuse should be assessed through passing off, requiring evidence of public confusion or false endorsement. Moreover, publicly available images should remain available for creative and fan expression unless their use is misleading, defamatory or otherwise unlawful.

Bhatia also argued that public figures retain privacy, but courts should weigh genuine public interest. Defamation claims should rarely prompt pre-trial restraints. Finally, personality rights should not extend to voice or mannerisms excluded from copyright protection.

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