Delhi High Court: In an application filed under Order 39 Rules 1 and 2 of the Civil Procedure Code, 1908, wherein the plaintiff, Abhishek Bachchan, sought a permanent injunction restraining Defendants 1 to 14 from infringement of copyright, performer’s rights, misappropriation of Personality Rights and passing off, the Single Judge Bench of Tejas Karia, J, held that the unauthorised use of Abhishek Bachchan’s persona constituted an infringement of his Personality Rights. Thus, the Court granted interim injunction in favour of Abhishek Bachchan and directed blocking and disabling of all infringing websites, platforms and YouTube channels disseminating content violating his Personality Rights.
Background
Abhishek Bachchan is a recognized actor, film producer and entrepreneur. Over the years, he has built a brand name for himself by carefully selecting which brands/products to endorse after a thorough background check of the brand, due to which the public associates ‘trust’ and ‘quality’ with his name and every brand he endorses.
On account of his reputation, Abhishek Bachchan’s name, image, signature, voice, likeness and all other elements of persona, constituting his Personality Rights, have acquired a unique distinctiveness, and due to their inimitable nature, they have a huge commercial value associated with them.
Defendants 1 to 8 operate and maintain websites that sell merchandise like t-shirts, stickers, posters, signed photographs, wallpapers etc. bearing the likeness of Abhishek Bachchan. Some of the infringing products are also available on e-commerce websites like amazon.
Defendant 9 is an e-commerce platform that unauthorizedly sells infringing t-shirts, coffee mugs, posters and other articles which violate his personality rights.
Defendants 10 to 14 are YouTube Channels which feature AI-generated videos of Abhishek Bachchan using his name, image and likeness in an unauthorised manner.
It was submitted that the entire business model of Defendants 1 to 14 was designed to illegally monetise Abhishek Bachchan’s persona for personal gain. The infringing activities conducted by Defendants 1 to 14 is without his consent and is debasing the goodwill and reputation he has carefully garnered over the many years. Additionally, the usage of Abhishek Bachchan’s name to host explicit videos/images or portraying him in an obscene setting is prejudicial to his reputation.
Analysis, Law and Decision
The Court noted that Abhishek Bachchan’s name, image, signature and persona are linked with his professional work and a misuse of the same has the effect of diluting his goodwill and reputation. The Court further noted that the use of technology to depict Abhishek Bachchan in settings that are misleading, derogatory or inappropriate, intrudes upon his right to privacy. Such misappropriation is further aggravated by the ease with which online content can be disseminated. The Court opined that any infringement of Abhishek Bachchan’s Personality Rights will lead to confusion amongst members of the public regarding the authenticity, endorsement or sponsorship of a product or service by him.
The Court observed that the infringing activities by Defendants 1 to 14 directly impacted the economic interests as well as the dignity of Abhishek Bachchan, potentially causing irreversible injury to his reputation and goodwill.
The Court also referred to cases of Amitabh Bachchan v. Rajat Negi, (2022) 6 HCC (Del) 641, and Anil Kapoor v. Simply Life India, 2023 SCC OnLine Del 6914, wherein the Delhi High Court had protected the Personality Rights of other prominent actors.
The Court opined that the misuse of Abhishek Bachchan’s name, image, signature, likeness and other elements of his persona clearly constituted infringement as the adoption of the aforementioned attributes without any authorization, would inevitably cause confusion and create a perception of endorsement by him. Thus, the Court held that a prima facie case had been established and the balance of convenience was also in Abhishek Bachchan’s favour. Further, irreparable loss, damage and injury would be caused not just financially but also with respect to his right to live with dignity and prestige if the interim injunction was not granted immediately.
Till the next date of hearing, the Court restrained:
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Defendants 1 to 14 and any persons acting on their behalf from violating Abhishek Bachchan’s Personality/Publicity/Moral Rights by utilizing directly or indirectly, his name, the acronym ‘AB’, his image, likeness or any other attributes of his persona which are exclusively identifiable with him, for any commercial or personal gain.
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Defendants 1 to 14 and any persons acting on their behalf, from creating, sharing, disseminating, any product, including T-shirts, coffee mugs, posters, and/or audio-visual content, created through Artificial Intelligence, that results in dilution of Abhishek Bachchan’s persona.
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Defendants 1 to 9, to take down, remove, disable and block the URLs selling infringing products on their websites, applications or platforms within 72 hours of receipt of notice.
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Defendant 15, Google LLC that owns the tool ‘YouTube’, to take down the channels posting AI-generated videos of Abhishek Bachchan within 7 days of receipt of notice.
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Defendants 16 and 17, i.e., the Ministry of Electronics and Information and Technology and the Department of Technology, Government of India, to issue necessary directions to block and disable all URLs posting infringing content or selling infringing merchandise within 7 days of receipt of notice.
The matter was further listed for 15-1-2026.
[Abhishek Bachchan v. The Bollywood Tee Shop, C.S.(COMM) No. 960 of 2025, decided on 10-9-2025]
Advocates who appeared in this case:
For the Plaintiff: Pravin Anand, Ameet Naik, Madhu Gadodia, Dhruv Anand, Udita Patro, Nimrat Singh, Deevesha Tudekar, Dhananjay Khanna, Aayushi Udani, Advocates
For the Defendants: Rohan Ahuja, Shruttima Ehersa, Devangini Rai, Aiswarya Debadarsini, Diya Viswanath, Jahanvi Agarwal, Advocates
