Delhi HC Grants Ex Parte Injunction to Yuvraj Singh Against AI Deepfakes and Unauthorised Merchandise

Justice Jyoti Singh restrained twelve defendants from exploiting the cricketer's name, image and likeness through AI-generated content and unlicensed merchandise, pending hearing.

On 29 July 2026, Justice Jyoti Singh, sitting singly at the High Court of Delhi, passed an ex parte ad interim injunction in favour of former Indian cricketer Yuvraj Singh, restraining twelve named defendants and unknown John Does from using his name, image, voice and likeness without authorisation. The suit, filed as a commercial suit before the Original Side of the court, targets a range of conduct: AI-generated deepfake posts and videos depicting events that never occurred, fabricated statements attributed to the plaintiff, and the sale of merchandise bearing his persona without consent. The court found a prima facie case, held that the balance of convenience lay with the plaintiff, and directed platform intermediaries to take down specific URLs within 24 to 36 hours.

The Conduct Complained Of

The plaintiff's plaint catalogues conduct across multiple platforms and defendants. Defendant No. 2, a Facebook profile called “Ramniwas Adv” with over 41,000 followers, published AI-generated images of the plaintiff at the Golden Temple with his head uncovered — described in the plaint as religiously insensitive and misleading. Defendant No. 3, a Facebook profile called “Cricket in India” with over 1.1 million followers, circulated AI images depicting a false scene of another cricketer touching the plaintiff's feet.

Several Instagram accounts feature in the plaint. Defendant No. 5 posted an AI-generated image alongside another cricketer with a superimposed caption said to be humiliating. Defendants No. 6 and 7 published AI-generated videos depicting the plaintiff as aggressive or violent, assaulting another cricketer. Defendant No. 8, an account called “memes____owner”, disseminated a digitally altered video with the plaintiff's face superimposed onto another person, accompanied by vulgar and abusive language. A Reddit account, Defendant No. 9, posted fabricated statements about the plaintiff's views on women.

Three merchants were also arrayed as defendants. Defendant No. 10, e-commerce entity NextPrint, manufactured and sold T-shirts bearing the plaintiff's name and likeness. Defendant No. 11, Turtle Wings, sold photo frames displaying elements of his persona. Defendant No. 12, SMEEPS, manufactured and sold stickers using his name and image. The plaintiff also impleaded Amazon Seller Services (Defendant No. 13), Flipkart Internet (Defendant No. 14), Meta Platforms (Defendant No. 15), and Reddit, Inc. (Defendant No. 16) as intermediary platforms.

Defendant No. 17 was identified as the Ministry of Electronics and Information Technology and Defendant No. 18 as the Department of Telecommunications.

Preliminary Applications: Mediation Exemption, Additional Documents, and Advance Notice

Before addressing the injunction application, the court disposed of three interlocutory applications. The first, under Order XI Rule 1(4) read with Section 151 CPC, sought leave to place additional documents on record. The court allowed the application, directing the plaintiff to comply strictly with the provisions of the Commercial Courts Act, 2015 for any future filings of additional documents.

The second application sought exemption from pre-institution mediation under Section 12A of the Commercial Courts Act, 2015. The court granted the exemption, citing the Supreme Court's decision in Yamini Manohar v. T.K.D. Keerthi, (2024) 5 SCC 815, and the Division Bench judgment of the Delhi High Court 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 third application, under Section 80(2) read with Section 151 CPC, sought exemption from serving advance notice on Defendants No. 17 and 18. The court allowed that application as well, exempting the plaintiff from serving advance notice on the Ministry of Electronics and Information Technology and the Department of Telecommunications. Defendants No. 17 and 18 were also exempted from filing written statements.

The Legal Basis: Personality and Publicity Rights

Plaintiff's counsel placed before the court a line of Delhi High Court precedents recognising and protecting personality rights. The court referred to 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; Sunil Gavaskar v. Cricket Tak (CRICKETTAK557) and Ors., CS(COMM) 1329/2025; and Jaikishan Kakubhai Saraf v. Peppy Store and Others, 2024 SCC OnLine Del 3664. The consistent position taken in these decisions is that unauthorised use of a person's name, image or other distinctive attributes for commercial purposes constitutes infringement, amounts to dilution of individual identity, and results in unearned commercial gain.

The court also invoked the Supreme Court's decision in R. Rajagopal Alias R.R. Gopal and Another v. State of T.N. and Others, (1994) 6 SCC 632, which disapproved any commercial misuse of a celebrity's name, voice, persona or likeness, holding that the right to privacy is violated when a person's name or likeness is used without consent for advertising or non-advertising purposes.

Justice Jyoti Singh held that Yuvraj Singh's stature inherently grants him proprietary rights over his personality and its associated attributes, giving him the exclusive right to use those attributes commercially and the right to prevent unauthorised exploitation by third parties. The court observed that violators of personality and privacy rights need to be dealt with a heavy hand.

Prima Facie Finding and the Balance of Convenience

The court's assessment of the injunction application under Order XXXIX Rules 1 and 2 read with Section 151 CPC proceeded on three fronts. On prima facie case, the court found that the impugned AI-generated posts and deepfake videos were tarnishing the plaintiff's goodwill and reputation, lowering his image in public eyes. The fabricated merchandise, bearing his images and creating a false impression of endorsement, was found to constitute passing off as well as violation of personality rights, diminishing the commercial value of his persona.

On balance of convenience, the court found it lay in the plaintiff's favour. On irreparable harm, the court held that the plaintiff was likely to suffer irreparable injury if the injunction was not granted, given his reputation, goodwill and public stature built over 17 years of international cricket.

The court noted the particular harm caused by AI-generated content: posts depicting events that have never occurred, superimposed faces in abusive or violent contexts, and fabricated statements about views the plaintiff has never expressed. It treated the use of AI tools, including deepfakes, face morphing and generative AI, as a category requiring explicit restraint in the order's terms.

Directions to Intermediaries

The court directed specific takedowns by platform intermediaries tied to a list of URLs in Annexure-A to the order. Defendant No. 15/Meta Platforms, Inc. was directed to take down URLs at serial nos. 1 to 7 of Annexure-A within 36 hours of receiving a copy of the order. Defendant No. 13/Amazon Seller Services Private Limited was directed to take down URLs at serial nos. 13 and 14, and Defendant No. 14/Flipkart Internet Private Limited was directed to take down URLs at serial nos. 15 and 16, both within 36 hours.

Defendant No. 11/Turtle Wings and Defendant No. 12/SMEEPS were each directed to take down their respective URLs within 24 hours. The shorter window for the direct merchants reflects the court's view of the more immediate commercial exploitation involved.

Reddit, Inc. (Defendant No. 16) was separately given 10 days to file a short reply in respect of the post described in paragraph 24 of the plaint. The court noted on record that the plaintiff's counsel had stated that the URLs at paragraph 25.1 of the plaint relating to Defendant No. 10 (NextPrint) were no longer accessible after the suit was filed.

Suit Procedure and Next Dates

The court directed that the plaint be registered as a commercial suit. Summons were issued, with counsel for Defendants No. 15 and 16 accepting service in court. For remaining defendants, summons were directed to be issued through all permissible modes upon filing of process fee, returnable before the Joint Registrar on 27 August 2026. Written statements are to be filed within 30 days of receipt of summons along with affidavits of admission and denial of documents. The plaintiff has 30 days from receipt of written statements to file replications.

Notice on the injunction application was issued and made returnable on 30 November 2026 for the remaining defendants. Defendants No. 15 and 16 accepted notice in court. The Joint Registrar was entrusted with admission and denial of documents and the marking of exhibits. The plaintiff was directed to comply with Order XXXIX Rule 3 CPC within two weeks.

The court also left it open to the plaintiff to approach the relevant intermediary or seek legal remedy if further infringing posts or videos come to light before the next date.