Delhi High Court: While considering a commercial suit seeking protection of personality, publicity and privacy rights against the unauthorised use and commercial exploitation of a celebrity’s persona, a Single Judge Bench of Jyoti Singh, J., granted an ex parte ad interim injunction in favour of former Indian cricketer Yuvraj Singh. Holding that the plaintiff-Yuvraj Singh had established a prima facie case, with the balance of convenience lying in his favour and a likelihood of irreparable harm in the absence of interim protection, the Court observed that Yuvraj Singh has an exclusive right to commercially exploit and protect his name, image, voice, likeness and other personality attributes, and that no third party can use the same without his consent or authorisation.
Observing that “violators of personality and privacy rights need to be dealt with a heavy hand”, the Court restrained the defendants from using or exploiting Yuvraj Singh’s personality attributes, including through artificial intelligence, generative AI, deepfakes, AI chatbots, face-swapping, face morphing or similar technologies. The Court also directed the concerned intermediaries and e-commerce platforms to remove the impugned URLs within the stipulated timelines and granted liberty to the plaintiff to seek appropriate remedies in respect of any future infringing content.
Background
The plaintiff, former Indian cricketer Yuvraj Singh, instituted a commercial suit seeking protection of his personality, publicity and privacy rights against the unauthorised use and commercial exploitation of his name, image, likeness, voice and other indicia of identity. Alleging that his personality attributes had acquired immense goodwill and commercial value through his distinguished cricketing career, public recognition and brand endorsements, the plaintiff contended that several social media accounts were publishing AI-generated images, videos and fabricated narratives falsely depicting him in objectionable, misleading and defamatory situations, thereby causing serious harm to his reputation and public image. Among the impugned posts, one AI-generated image falsely depicted the plaintiff at the Golden Temple with his head uncovered, flagged by the Court as religiously insensitive and misleading, while a fabricated Reddit post titled “Yuvraj and his view on women” attributed to him opinions he had never expressed
It was further alleged that certain e-commerce entities were manufacturing and selling merchandise bearing the plaintiff’s name, image and likeness without his authorisation, creating a false impression of endorsement and commercially exploiting his persona. Invoking the Delhi High Court’s jurisprudence on personality and publicity rights, the plaintiff sought an ex parte ad interim injunction restraining the defendants from further infringement, directing removal of the impugned content and preventing any unauthorised commercial use of his personality attributes.
Analysis
The Court held that the plaintiff had made out a prima facie case for grant of an ex parte ad interim injunction, observing that the balance of convenience lay in his favour and that he was likely to suffer irreparable harm if interim protection was denied. Reiterating the settled position that personality rights are enforceable in law, the Court observed that the plaintiff had an exclusive right to protect and commercially exploit his name, image, likeness, voice and other attributes of his persona, and no third party could use them without his consent or authorisation. Referring to D.M. Entertainment v. Baby Gift House, 2010 SCC OnLine Del 4790; Anil Kapoor v. Simply Life India, 2023 SCC OnLine Del 6914; Sunil Gavaskar v. Cricket Tak1; Jaikishan Kakubhai Saraf v. Peppy Store, 2024 SCC OnLine Del 3664; and R. Rajagopal v. State of T.N., (1994) 6 SCC 632, the Court reiterated that unauthorised commercial use of a celebrity’s personality attributes amounts to infringement of personality rights, dilution of identity and unjust commercial gain.
Recognising Yuvraj Singh as one of India’s most celebrated cricketers whose achievements, goodwill and philanthropic work had earned him immense public recognition and proprietary rights over his personality attributes, the Court found that the AI-generated posts, deepfake videos and fabricated content published by Defendants 1 to 9 falsely portrayed events that had never occurred, tarnished Yuvraj Singh’s reputation and lowered his image in the eyes of the public. It further held that the unauthorised sale of merchandise bearing Yuvraj Singh’s name and likeness by Defendants 10 to 12 amounted to passing off and unlawful commercial exploitation of his personality rights.
Decision
Observing that “violators of personality and privacy rights need to be dealt with a heavy hand”, the Court restrained the defendants from using or exploiting the Yuvraj Singh’s personality attributes, including through artificial intelligence, generative AI, deepfakes, face-swapping or similar technologies, and directed Amazon, Flipkart, and Meta to take down the impugned URLs within 36 hours, and the two merchandise sellers, Turtle Wings and SMEEPS, to do so within 24 hours. The Court also granted liberty to the plaintiff to approach the intermediaries or avail appropriate legal remedies in respect of any future infringing content.
[Yuvraj Singh v. Ashok Kumar, CS(COMM) 796 of 2026, decided on 29-7-2026]
Advocates who appeared in this case :
For the Plaintiff: Gaurav Bahl, Anku Khanna, Arundhati Dhar, Harshita, Sachin Thakkar, Ritika Pandey and Deepa Rathi, Advocates
For the Defendants: Amee Rana, Sana Bamyal, Tanvi Raina, Ankit Parhar and Shreya Gupta, Advocates
1. CS (COMM) 1329/2025.