Delhi High Court: While considering a suit filed under Order 39, Rules 1 and 2 CPC, seeking ad-interim injunction restraining trade mark infringement, passing off and misappropriation of personality and performer’s rights of content creator Raj Shamani (Plaintiff 1), the Single Judge Bench of Manmeet Pritam Singh Arora, J, held that Raj Shamani is a known face in the field of content creation in India and has attained sufficient goodwill and reputation.
Thus, the Court restrained the defendants from misusing Raj Shamani’s persona, name, image, likeness or voice in any manner for any personal or commercial use.
Background
Plaintiff 1 is an Indian content creator, entrepreneur, podcaster, speaker, author and host of the podcast series ‘Figuring Out with Raj Shamani’ (‘the podcast’). Plaintiff 2 is engaged in the business of creation, management, distribution and production of audio-visual content along with other related activities and is the owner of the podcast. Plaintiff 1 is the registered trademark owner of the wordmark ‘FIGURING OUT’ and the device mark 
The plaintiffs’ podcast has featured several accomplished personalities from diverse fields such as business, sports, entertainment and politics. Plaintiff 1 has numerous sponsorships for his podcast as well as endorsement partnership with highly reputed corporate entities. He has won several national and international accolades. He has also represented India at the United Nations at the age of 16 and is a brand ambassador for ASUS ExpertBook Series.
It was contended that Plaintiff 1’s personality, goodwill and reputation are intrinsically tied to his name, voice, image, likeness, and other characteristics that are uniquely identifiable and exclusively associated with him. It was further submitted that no one can utilize and/or misrepresent these attributes including through artificial intelligence, voice cloning, or other digital means for misleading the public or deriving commercial gain in any manner whatsoever, without the consent and/or express authorization of the Plaintiff 1.
It was submitted that Defendants 1-5, 10, 16, 19 and 20 are a range of digital entities and online platforms engaged in unauthorized use of Plaintiff 1’s name, voice, image and likeness.
Defendant 1 are unknown entities that have been unauthorizedly using and reproducing the clips from Plaintiff 1’s podcast on their YouTube channels.
Defendant 2 is an online platform which falsely and unauthorizedly purports to provide bookings with Plaintiff 1 for commercial engagements. Defendant 3 is a digital booking marketplace, that without any authorization or arrangement with Plaintiff 1, publicly lists him as a speaker and influencer available for professional engagements. Defendant 4 is an online entertainment booking portal that without the authorization of the Plaintiff 1 claims to ensure scheduling of bookings with him for interview/podcast or other commercial engagements for consideration of a sum quoted by itself.
Defendant 5 provides services of filing taxes, returns and other tax related services and it has featured Plaintiff 1’s name and image without consent or authorization implying endorsement or affiliation with Plaintiff 1.
Defendant 10 reproduces and republishes the video content of Plaintiff 1 in a manner that misleads users into believing that Plaintiff 1 is associated with it.
Defendant 16 is an independent YouTube channel which copies the visual style of Plaintiff 1, including the device mark 
Defendants 19 and 20 are companies engaged in the manufacture and distribution of Himalayan water and dietary supplements, respectively. They are unauthorizedly using the Plaintiff’s podcast to falsely imply endorsements, collaboration or affiliation with their brands and services.
Analysis, Law and Decision
The Court noted that Plaintiff 2 is the exclusive owner and producer of all content created and disseminated under the banner of Plaintiff 1’s official digital platforms. It holds the exclusive copyright and all associated rights in respect of the content produced and published on such platforms, including the podcast.
The Court opined that on the basis of the material-on-record, it was evident that Plaintiff 1 a known face in India, especially in the field of content creation and has gained goodwill and reputation over a course of a successful career.
The Court further stated that,
“The actions of the infringing defendants which use Plaintiff 1’s name and image to represent association and endorsement of their products and services also lends credence to Plaintiff 1’s submissions that he has publicity rights. In these facts, it prima facie appears to this Court that Plaintiff 1 enjoys publicity rights with respect to its personality which is a valuable right for him.”
Thus, the Court opined that Plaintiff 1’s name, likeness, voice and image are protectable elements of his personality rights and as such he is entitled to seek an injunction protecting the same. The Court also stated that Plaintiff 1 is entitled to protect himself against morphed and distorted content which is defaming and demeaning or patently false as it is bound to affect his reputation and goodwill.
Accordingly, the Court passed the following directions:
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Defendants 1-5, 10, 16, 19 and 20 and every person or entity acting on their behalf were restrained from directly or indirectly misusing or exploiting the name, likeness, image, photos or videos of Plaintiff 1 without his express authorization. The said defendants were also restrained from infringing the registered trade marks ‘FIGURING OUT’ and
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Defendants 6,7 and 11 were directed to take down or block the infringing posts and videos. They were also directed to disclose to the plaintiffs the BSI details and all other details available with them of the uploaders of the links pertaining to unknown entities enlisted as Defendant 1.
The matter was further listed for 24-4-2026.
[Raj Shamani v. John Doe, C.S. (COMM) No. 1233 of 2025, decided on 17-11-2025]
Advocates who appeared in this case :
For the Plaintiffs: Diya Kapur, Senior Advocate, Nakul Gandhi, Mujeeb, Tanish Gupta, Siddhi Sahoo, Avi Kaushik, Aditya Lodha, Advocates
For the Defendants: Madhav Khosla, Amee Rana, Sana Banyal, Varsha Jhavar, Aditya Mathur, Nidhi Raman, Om Ram, Arnav Mittal, Mayank Sansanwal, Advocates