Disclaimer: This has been reported after the availability of the order of the Court and not on media reports so as to give an accurate report to our readers.
Delhi High Court: In a commercial suit was instituted by the plaintiff, Mr. Nandamuri Taraka Rama Rao, a well-known Indian actor and cultural icon in Telugu cinema, seeking permanent injunction and ancillary reliefs against misappropriation of his personality and publicity rights, infringement of copyright, and unauthorised commercial exploitation of his name, image, likeness and associated attributes, a Single-Judge bench of Manmeet Pritam Singh Arora, J., grants ex-parte injunction protecting Junior NTR’s personality and publicity rights against unauthorised merchandise and digital exploitation.
The plaintiff asserted that the plaintiff has he received wide-ranging recognition through filmography includes RRR (2022), which brought him international recognition and prestigious cinema accolades. The plaintiff also highlighted his philanthropic and humanitarian initiatives and stated that these contributions have generated enormous goodwill and public recognition, establishing him as a household name not only in Telangana and Andhra Pradesh but across India and internationally.
The plaintiff contended that he is one of the most sought-after brand ambassadors in India, with an estimated brand value exceeding ₹400 crores. It was argued that his success is closely linked to the unique and identifiable attributes of his personality, including his name, image, likeness, nicknames and sobriquets, all of which constitute protectable personality and publicity rights.
The plaintiff specifically pleaded that his name “Nandamuri Taraka Rama Rao”, known identities such as “NTR”, “Jr. NTR”, “NTR Jr.”, and sobriquets including “Man of Masses”, “Young Tiger” and “Tarak”, have acquired distinctiveness and are exclusively associated with him. He further placed on record that he holds valid and subsisting trademark registrations for, inter alia, “NTR”, “JR. NTR”, “NANDAMURI”, “NANDAMURI TARAKA RAMA RAO” and “MAN OF MASSES” across Classes 1 to 45.
The plaintiff contended that several defendants, including online sellers, merchandise manufacturers, and e-commerce platforms, were unauthorisedly manufacturing, selling, promoting and facilitating the sale of infringing merchandise bearing his name, image and likeness. It was also alleged that impersonation and AI-generated, morphed and manipulated content was being circulated for commercial gain, causing deception, confusion, economic loss and reputational harm.
The Court observed that the documents placed on record clearly establish that the plaintiff is “a known and recognised actor whose name, image, and likeness have acquired goodwill through decades of professional achievement and brand endorsements.” The Court noted that the plaintiff has millions of followers across social media platforms and several brand endorsement agreements and is a sought-after brand ambassador. The Court held that these facts “holistically establish the public association uniquely tied to his identities and his reputation amongst the public.”
The Court further took note of the plaintiff’s trademark registrations in respect of his name and its variations, and held that, prima facie, the plaintiff is “a well-known face in India who has gained immense goodwill and reputation over a course of a successful career and has acquired a celebrity status in India.”
Relying on D.M. Entertainment (P) Ltd. v. Baby Gift House, 2010 SCC OnLine Del 4790; Anil Kapoor v. Simply Life India, 2023 SCC OnLine Del 6914 and Jaikishan Kakubhai Saraf v. The Peppy Store, (2024) 2 HCC (Del) 253, the Court held that celebrity status inherently grants proprietary rights over personality and associated attributes. The observed that there could be “no dispute that this celebrity status inherently grants the Plaintiff proprietary rights over his personality and associated attributes.”
The Court held that the plaintiff’s name, likeness and image are protectable elements of his personality rights, and that he is entitled to seek injunction against third parties using these attributes for selling merchandise for commercial gain without authorisation.
On the tests of prima facie case, balance of convenience and irreparable injury, the Court found that the balance of convenience lay in favour of the plaintiff and that continued availability of infringing merchandise would cause irreparable injury to his reputation and goodwill.
The Court granted an ex-parte ad-interim injunction, restraining the infringing defendants, their associates and all persons acting through them from utilising, exploiting or misappropriating the Actor Junior NTR’s Personality Rights and Publicity Rights, including his name, styles, photographs and likeness, through any medium or technology, including artificial intelligence and generative AI, for any commercial gain without authorisation.
The Court directed the concerned defendants to take down all infringing links listed in Annexure-A to the order and were restrained from selling or facilitating the sale of infringing merchandise. The Court directed the E-commerce platforms to delist the impugned goods, and compliance was mandated within 72 hours from receipt of the order. The Court also directed search engines to re-index infringing URLs in the event of non-compliance by the sellers and issued further directions to intermediaries to examine additional URLs in accordance with the IT Rules, 2021.
[Nandamuri Taraka Rama Rao v. Ashok Kumar, 2025 SCC OnLine Del 9417]
Advocates who appeared in this case:
Mr. J. Sai Deepak, Sr. Adv., Dr. Alka Dahar Adv., Mr. Shiv Verma Adv., Mr. B. Sidhi Pramodh Rayudu Adv., Ms. Purnima Vashishtha Adv., Mr. Varun Sharma Adv., Ms. Khushi Jain Adv. and Ms. Pankhudi Tripathi Adv., Counsel for the Plaintiff
Mr. Manas Raghuvanshi, Adv., Counsel for D- 12.
Ms. Mishthi Dubey, Adv., Counsel for D-15.
Ms. Shilpa Gupta and Ms. Surabhi Pande, Adv., Counsel for D-16 & 17.
Mr. Aditya Gupta & Ms. Vani Kaushik and Mr. Rohith, Advs., Counsel for D-23.
Mr. Varun Pathak, Ms. Amee Rana, Ms. Sana Banyal & Ms. Anannya Gogoi, Advs., Counsel for D-24.
Mr. Ankit Parhar, Mr. Abhishek Kumar, Ms. Shreya Gupta and Ms. Sanchli Sethi, Advs., Counsel for D-25/X Corp.
Mr. Ankit Parhar & Ms. Shreya Gupta, Advs., Counsel for D-26/Reddit. Inc
Mr. Siddhartha Shankar Ray, CGSC with Mr. Atishay Jain, Adv., Counsel for D-27 and D-28