Delhi High Court: While hearing an application for an ad interim injunction filed by Telugu actor, Akira Nandan, seeking to restrain Defendant 1 from further disseminating the AI movie created by Defendant 1 wherein the plaintiff’s person has been used without authorization, the Single Judge Bench of Tushar Rao Gedela, J, held that the usage of AI tools to morph, modify or distort aspects of the plaintiff’s persona to create deepfake images and videos was violative of the plaintiff’s right to privacy as well as his personality and publicity rights.
Accordingly, the Court granted an ex parte injunction in favor of the plaintiff.
Background
The plaintiff is a 21-year-old student belonging to the illustrious Konidala family of the Telugu Entertainment Industry. The plaintiff’s father is a renowned, well-known and popular film actor and is presently the deputy Chief Minister of the State of Andhra Pradesh. Plaintiff’s mother is an acclaimed actress, director and producer. On account of the lineage and popularity in the entertainment industry, the plaintiff is claimed to have developed a distinct, recognizable, independent public persona, goodwill and reputation. Plaintiff claims that his name, image, likeness, voice and identity enjoy substantial public recognition and carries significant reputational and commercial value which renders the plaintiff susceptible to unlawful exploitation. The plaintiff further claimed that from a young age, he has been called by several names such as ‘KONIDALA KID’, ‘POWER STAR KID’, ‘RISING STAR KID AKIRA’ and is widely recognised as a ‘PSPK STAR KID’ in the popular industry discourse.
According to the plaintiff, Defendant 1 has created and posted on YouTube, a full movie of around one hour, allegedly claiming to be the world’s first global AI movie that features the plaintiff in the lead role without his authorization or permission clearly violating his right to privacy as also his personality rights containing complete attributes of the plaintiff’s persona, image, photograph with such accuracy as to synthetically create the AI avatar of the plaintiff in the movie. Plaintiff also claims that the AI morphing content portraying fabricated intimate/romantic scenes involving the plaintiff without any authorisation has already had, and has the potential to irreparably damage his name, image, goodwill and reputation resulting from the infringement of the copyright of his personality.
Analysis, Law and Decision
The Court noted that the plaintiff was popular in the public, had appeared in a movie as well as contributed to the music in the Telugu movie ‘OG’, implying that he has a noticeable presence in the entertainment industry. The Court further observed that the very act of deploying AI tools to create a movie with the plaintiff in the lead role, itself is a testament to his distinctive image and persona. The Court further stated that there is every likelihood of exploitation of his name, image, picture, personality, voice, etc.
The Court opined that it was of the prima facie view that the plaintiff had a strong case and that the balance of convenience was in his favor. The irreparable injury and loss that the plaintiff may suffer, if no restraint orders are passed, would be irreparable inasmuch as, a dent to the personality and the very image of the plaintiff, can neither be measured in monetary terms nor be resurrected conveniently.
Accordingly, the Court granted an ex-parte ad interim injunction in favor of the plaintiff and directed that:
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The defendants and all persons acting on their behalf were restrained from creating, publishing or making available to the public the impugned AI-generated movie misusing the plaintiff’s persona, as well as any other content exploiting or misappropriating the plaintiff’s personality traits.
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Defendants, including john does were restrained from violating the plaintiff’s personality / publicity rights by utilizing in any manner and/or directly and/or indirectly, using or exploiting or misappropriating any facets of the plaintiff’s personality traits, including:
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His name ‘Akira’, ‘Akira Nandan’, ‘Akira Desai’ or any other variant
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His photographs, image, likeness
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Visuals, voice and speech patterns
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any other attributes of his persona which are exclusively identifiable with him
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any deepfake, morphed, superimposed, or manipulated content,
for any commercial or personal gain without the plaintiff’s authorization or consent.
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Defendant 3, Meta, was directed to inform the user of the infringing URLs to be taken down.
The matter was further listed for 5-2-2026.
[Akira Desai alias Akira Nandan v. Sambhawaami Studios LLP, 2026 SCC OnLine Del 283 decided on 23-1-2026]
Advocates who appeared in this case:
For the Plaintiff: J. Sai Deepak, Senior Advocate, Himanshu Deora, Rahul Mehta, Arpit Choudhary, Kunal Mehta, Anupriya Alok, Sanat Saswadkar, Advocates
For the Defendants: Aditya Gupta, Vani Kaushik, Varun Pathak, Yash Karunakaran, Prasidhi Agrawal, Advocates