Delhi High Court bars Kriti Sanon deepfakes and fake accounts, and says personality rights are not one claim
Justice Purushaindra Kumar Kaurav granted interim relief against AI content, explicit deepfakes and fake accounts, and set out that each personality claim carries its own elements and defences.
The Delhi High Court has granted actor Kriti Sanon interim protection against the misuse of her name, image, likeness and voice through AI-generated content, sexually explicit deepfakes and impersonating accounts. Justice Purushaindra Kumar Kaurav passed the order in Sanon's suit seeking protection of her personality and publicity rights. The matter is listed for further hearing on 10 December.
The order does two things. It gives Sanon specific, content-based relief against identified material, and it records how the Court reads the law of personality rights.
What Sanon complained of
Sanon told the Court that various persons and entities were misusing her name, image, likeness and voice. The alleged misuse included offering bookings for her appearances and impersonating her through social media accounts.
She also pointed to AI-generated and morphed images, the sale of merchandise, and AI chatbots and synthetic voice models presented as the actor. Websites hosting pornographic deepfakes were part of the complaint.
The directions Justice Kaurav issued
The Court directed the defendants to take down the URLs identified in the suit. It restrained them from uploading, hosting, generating or making available further material of a similar nature.
The restrained material includes content impersonating Sanon or falsely representing an association with her. It also covers sexually explicit, obscene or morphed images, videos or audio, AI chatbots and voice models presented as the actor, and merchandise of the kind placed on record.
Intermediaries must take down or disable access to the identified URLs within the time prescribed under the Information Technology Rules, 2021. The Court also directed the authorities concerned to issue blocking directions against websites hosting pornographic deepfakes.
What the injunction leaves alone
The injunction does not restrain news, reviews, criticism, commentary, satire, parody, caricature or fan expression that falls outside the specified directions. The Court also said its findings were prima facie and confined to the interim arrangement.
It observed that the questions on personality rights raise complex legal issues. Those will be decided after the contesting defendants are heard.
Personality rights as a bundle of claims
The Court treated personality rights as a description rather than a legal claim of its own. In its words, “‘Personality rights’ is not a single cause of action.”
It is, the Court said, a description of several distinct claims that may arise when a person's identity is used without consent. It named the right of publicity, passing off, the right of privacy and defamation.
Where their conditions are met, it added, rights under the Trade Marks Act, 1999 and the Copyright Act, 1957 also apply, including performers' rights. Each claim, the Court said, carries its own elements, defences and remedy. Putting them under one label cannot lower the threshold that applies to any one of them.
A plaintiff must therefore specify, defendant-wise and content-wise, the claims made and the material supporting them. The Court said all claims cannot be placed under one umbrella to seek a blanket injunction.
Commercial value against dignity
The Court observed that the right of publicity protects the commercial value of an individual's identity and can be licensed. Privacy, dignity and reputation are personal interests that cannot be assigned.
On who may sue, it said: “Fame bears on whether an identity has commercial value and on the loss caused by its misuse; it is not a condition of the right.” It added that “the mere use of a person's identity is not, by itself, unlawful.”
The constitutional root: Article 21
The privacy strand rests on the Constitution. In Justice K.S. Puttaswamy v Union of India, (2017) 10 SCC 1, decided on 24 August 2017, a nine-judge Bench held privacy to be a constitutionally protected right emerging primarily from the guarantee of life and personal liberty in Article 21.
The judgment describes privacy as the constitutional core of human dignity and as the individual's control over his or her personality. It also calls natural rights inalienable because they are inseparable from the human personality, which sits alongside the Delhi High Court's statement that privacy and dignity cannot be assigned.
Puttaswamy drew on R. Rajagopal v State of Tamil Nadu, (1994) 6 SCC 632. Rajagopal recognised two aspects of privacy: an action in tort for damages for unlawful invasion, and a constitutional right.
Stephen Gardbaum, writing on horizontal effect in The Oxford Handbook of the Indian Constitution, notes that Rajagopal also suggested the right may apply against private actors. Deepfake and impersonation suits are typically brought against private persons.
The Delhi publicity cases before Sanon
The right of publicity entered Delhi law through commercial disputes. In ICC Development (International) v Arvee Enterprises (2003), the High Court tied the right to privacy and to an individual's identity markers, such as name and voice, and declined to extend it to a corporate event organiser.
In Titan Industries v Ramkumar Jewellers (2012), the Court restrained a jeweller's advertising that used images of Amitabh Bachchan and Jaya Bachchan. Amitabh Bachchan obtained a further injunction covering his name, voice and image in 2022.
An early order dealing with AI-driven misuse came in Anil Kapoor v Simply Life India, decided on 20 September 2023 by Justice Prathiba M. Singh. It protected the actor's name, image, voice and likeness against misuse that included AI tools, and it ran against unnamed defendants as well.
Similar orders followed for Jackie Shroff in 2024 and for Aishwarya Rai Bachchan and Abhishek Bachchan in September 2025. Sanon's order adds a statement of how each claim must be pleaded.
Statutes behind each claim
Passing off survives the Trade Marks Act, 1999 through section 27(2), which preserves rights of action for passing off. The classical elements include a misrepresentation made in the course of trade that is calculated to injure the goodwill of another.
Section 14 of the 1999 Act separately restricts registration of a mark that falsely suggests a connection with a living person, or one who died within twenty years, unless that person or the legal representative consents.
Under the Copyright Act, 1957, an actor is a performer within section 2(qq). The 2012 amendments, through sections 38A and 38B, gave performers exclusive rights and moral rights that survive an assignment of the economic rights.
The Information Technology Act, 2000 reaches the conduct from other sides. Section 66C punishes fraudulent use of another person's unique identification feature, section 66D punishes cheating by personation using a computer resource, and sections 67 to 67B deal with obscene and sexually explicit electronic material.
Section 79 gives intermediaries safe harbour. In Shreya Singhal v Union of India, (2015) 5 SCC 1, the Supreme Court read down section 79(3)(b) so that the duty to remove content arises on actual knowledge through a court order or a government notification, and it upheld the blocking power in section 69A.
Rule 3(2)(b) of the Information Technology Rules, 2021 requires intermediaries to act on an individual's complaint about content showing nudity or a sexual act, or impersonating the individual, including artificially morphed images. In February 2026 the Rules were amended to define synthetically generated information and to require prominent labelling of permitted synthetic content.
The larger question before a coordinate bench
A coordinate bench is dealing with a larger question on personality rights in the suits filed by actors Janhvi Kapoor, Vivek Oberoi and Aradhya Bachchan. Advocates Gautam Bhatia and Rohan Alva have been appointed as amici in those matters.
Bhatia submitted that a standalone claim for personality rights, accompanied by a broad John Doe injunction against unknown individuals, is unknown to Indian law. He argued that the expression covers a bundle of distinct legal interests, protected through different causes of action and remedies, and does not give rise to a uniform remedy such as a dynamic injunction.
The interim arrangement in Sanon's suit stands until the Court hears the contesting defendants. The matter is listed for further hearing on 10 December.