Delhi HC Grants Ex Parte Injunction to Cricketer Abhishek Sharma Against AI Deepfakes and Unauthorised Merchandise
Justice Jyoti Singh restrained social media accounts, e-commerce sellers, Amazon, Flipkart, and Meta from exploiting cricketer Abhishek Sharma's name, image, and likeness without consent.
On 9 July 2026, Justice Jyoti Singh of the High Court of Delhi, sitting singly, granted an ex parte ad interim injunction in favour of Indian cricketer Abhishek Sharma, restraining nineteen defendants — including anonymous social media accounts, e-commerce merchandise sellers, Amazon, Flipkart, Meta Platforms, and X Corp — from using his name, image, voice, likeness, or any other attribute of his persona without authorisation. The suit, registered as CS(COMM) 702/2026, was filed after the Plaintiff found AI-generated images, morphed videos, false rumours, and unauthorised merchandise circulating across Facebook, Instagram, and e-commerce platforms. The Court held that a prima facie case was made out, that the balance of convenience lay with the Plaintiff, and that irreparable harm would follow if interim relief were denied.
The Plaintiff and His Persona
Abhishek Sharma is described in the plaint as a well-known Indian cricketer of national and international repute. He led India's Under-19 team to victory at the Youth Asia Cup in 2016 and was part of India's winning squad at the ICC Under-19 World Cup in 2018. He made his senior international debut on 6 July 2024, during India's tour of Zimbabwe, and scored his maiden T20 International century in his second match, becoming one of the fastest Indian players to achieve that milestone.
In 2025, he recorded the highest individual score by an Indian player in T20 Internationals — 135 runs — and subsequently attained the No. 1 position in the ICC Men's T20 International rankings. At the 2025 Asia Cup, he was the highest run-scorer with 314 runs and was named Player of the Tournament. He was recognised as Wisden Leading T20 Cricketer in the World for 2026 and named ICC Men's Player of the Month for September 2025. Across approximately 46 international matches, he scored approximately 1,438 runs.
In franchise cricket, Sharma was picked by Delhi Daredevils in 2018 and, in the 2025 IPL season, scored 141 runs off 55 balls — the highest individual score by an Indian player and the third-highest in IPL history. His social media presence includes approximately 10.4 million Instagram followers. Leading brands including Titan, Gillette, Colgate, Coca-Cola, and Garnier have engaged him as a brand ambassador.
What the Defendants Were Doing
The plaint identified nineteen defendants across different categories. Defendants 1 to 8 were social media accounts on Facebook and Instagram alleged to be publishing AI-generated images, deepfakes, morphed photographs, and false content involving the Plaintiff.
Specifically, Defendant No. 2 — a Facebook profile called “Cricket zone” with approximately 1,24,000 followers — was publishing AI-generated images falsely depicting events that never occurred. Defendant No. 3, an Instagram account named “sdcricfact661”, was disseminating videos with superimposed text containing false statements about the Plaintiff; those videos had garnered more than 2,70,000 views. Defendant No. 4, a Facebook account called “Mahakal”, was creating AI-generated images of the Plaintiff with the CEO of franchise Sunrisers Hyderabad in an obscene manner. Defendants 5 and 6, both Instagram accounts, were spreading morphed images with misleading captions or abusive superimposed language. Defendant No. 7, a Facebook account called “Cricket In India” with over one million followers, was publishing obscene AI-generated images, as was Defendant No. 8, an Instagram account.
Defendants 9 to 12 were e-commerce sellers. Defendant No. 9 — “The Pop Tees” (legal name: Twin Tigers) — was selling T-shirts bearing the Plaintiff's name and likeness without authorisation. Defendant No. 10 (“Your Jersey”) was selling apparel including jerseys featuring his name and image. Defendant No. 11 (“Neon Attack”, trade name for Salasar Trading Co.) was selling photo frames displaying his image. Defendant No. 12 was offering posters featuring his name and image for commercial sale.
Defendants 14 and 15 — Amazon and Flipkart — were alleged to be hosting these unauthorised products on their marketplace platforms. Defendant No. 16 (Meta Platforms, Inc.) owns Instagram and Facebook, which were hosting the infringing content uploaded by Defendants 2 to 8. Defendant No. 17 (X Corp.) was hosting infringing posts by Defendant No. 13. Defendants 18 and 19 — the Ministry of Electronics and Information Technology (MeitY) and the Department of Telecommunications (DoT) respectively — were impleaded to facilitate implementation of Court orders.
Procedural Applications and How the Court Dealt with Them
Before registering the suit, the Court disposed of three interlocutory applications.
The first, I.A. 17025/2026, sought exemption from pre-institution mediation under Section 12-A of the Commercial Courts Act, 2015. Justice Singh granted the exemption, relying on the Supreme Court's judgment in Yamini Manohar v. T.K.D. Keerthi, (2024) 5 SCC 815, and the Delhi High Court Division Bench's judgment in Chandra Kishore Chaurasia v. RA Perfumery Works Private Ltd., 2022 SCC OnLine Del 3529, both of which support exemption where urgent relief is sought.
The second, I.A. 17026/2026, sought exemption from the mandatory notice requirement under Section 80(1) CPC before suing government bodies — in this case, MeitY (Defendant No. 18) and DoT (Defendant No. 19). The Court granted exemption given the urgency of the relief sought and the need for hearing on the same day.
The third, I.A. 17024/2026, was filed under Order XI Rule 1(4) read with Section 151 CPC to place additional documents on record. The Court allowed this application but directed that any further additional documents be filed strictly in accordance with the provisions of the Commercial Courts Act, 2015.
On the injunction application, I.A. 17023/2026, filed under Order XXXIX Rules 1 and 2 read with Section 151 CPC, the Court proceeded to grant ex parte ad interim relief after hearing the Plaintiff's counsel and examining the documents on record.
How the Court Reasoned on Personality Rights
Justice Singh reaffirmed that personality rights — encompassing a person's name, image, voice, likeness, and other distinctive personal attributes — are recognised and protected under Indian law. The Court cited three of its own earlier decisions: D.M. Entertainment v. Baby Gift House and Others, 2010 SCC OnLine Del 4790; Anil Kapoor v. Simply Life India and Others, 2023 SCC OnLine Del 6914; and Jaikishan Kakubhai Saraf v. Peppy Store and Others, 2024 SCC OnLine Del 3664. All three established that unauthorised commercial use of a person's name, image, or other distinctive attributes constitutes infringement of their rights, amounts to dilution of individual identity, and confers unearned commercial gain on the exploiter.
The Court also drew on its own recent order in Sunil Gavaskar v. Cricket Tak (CRICKETTAK557) and Ors., CS(COMM) 1329/2025, decided on 23 December 2025, in which similar relief was granted by restraining defendants from misusing Gavaskar's name, image, likeness, and signature. The Court noted that infringing content of this kind causes irreparable injury to a person of the Plaintiff's reputation and stature.
The Court further referred to the Supreme Court's judgment in R. Rajagopal Alias R.R. Gopal and Another v. State of T.N. and Others, (1994) 6 SCC 632, which disapproved any commercial or non-commercial misuse of a celebrity's name, voice, persona, or likeness and held that such use without consent violates the right to privacy.
Applying these principles, Justice Singh found that Abhishek Sharma had established a prima facie case. The content uploaded by Defendants 1 to 8 was false, obscene, and portrayed the Plaintiff in a damaging light, attributing to him acts and words that were untrue. The merchandise sold by Defendants 9 to 12 exploited his name and image for commercial gain without consent and without any authorisation, directly impacting his commercial value. The balance of convenience lay with the Plaintiff, and the harm from denial of injunction would be irreparable.
Directions Issued
The Court issued specific restraint orders and takedown directions operative until the next date of hearing.
Defendants 1 to 8, and those acting on their behalf, were restrained from using, directly or indirectly, the Plaintiff's name (Abhishek Sharma), image, voice, or likeness, or any other attribute of his persona, without authorisation, for any commercial or personal gain through technology or any other medium. They were also restrained from creating, publishing, uploading, sharing, re-sharing, disseminating, or amplifying any photographs, audio recordings, video recordings, or other audio-visual content featuring or using any attributes of his persona, including through style of speech, face swapping, morphing, superimposing, AI-generated content, or deepfake representation. Publishing or circulating false or obscene content concerning the Plaintiff was also specifically prohibited.
Defendants 9 to 12 and those acting on their behalf were restrained from manufacturing, listing, advertising, offering for sale, or selling any merchandise — including T-shirts, jerseys, photo frames, art, and posters — bearing the Plaintiff's name, image, likeness, or any other personality attributes without his authorisation.
For takedowns, Defendant No. 16 (Meta) was directed to remove two Instagram URLs set out in Annexure-A. Defendant No. 9 was directed to take down three product URLs from its website. Defendant No. 10 was directed to remove one product URL. Defendant No. 12 was directed to remove two URLs from its website. Defendant No. 14 (Amazon) was directed to take down four product listings. Defendant No. 15 (Flipkart) was directed to remove four product listings. All directed takedowns were to be completed within 36 hours of receipt of the order.
The Court also directed that summons be issued to Defendants 2 to 8 and 13 through their social media handles; to Defendants 9 to 12 through their social media handles as well as all permissible modes; and to Defendants 15, 18, and 19 through all permissible modes, returnable before the Joint Registrar on 11 August 2026. The injunction application itself is returnable before the Court on 17 November 2026. The Plaintiff was directed to comply with Order XXXIX Rule 3 CPC within two weeks of the order date.
Outcome
All three interlocutory applications filed by the Plaintiff — for exemption from pre-institution mediation, exemption from Section 80(1) CPC notice, and permission to place additional documents — were allowed and disposed of. The plaint was registered as a suit and summons were issued. The ex parte ad interim injunction under Order XXXIX Rules 1 and 2 was granted as directed above. The matter is listed before the Joint Registrar on 11 August 2026 for the returnable summons, and before the Court on 17 November 2026 for the injunction application.