Delhi High Court: While hearing a plaint filed by the famous actress Sonakshi Sinha seeking protection of her personality rights, the Single Judge Bench of Jyoti Singh, J., held that the voice, name, likeness, etc. of Sonakshi Sinha were exclusively attributable to her. Thus, the Court granted an ex parte ad interim injunction in favour of Sonakshi Sinha, restraining the defendants from creating or disseminating any AI-generated pictures, videos or merchandise that misuses and infringes upon the personality rights of Sonakshi Sinha.
Background
The plaintiff, Sonakshi Sinha is a well-known actress in Indian cinema and made her debut in 2010 with the film Dabangg which was a huge commercial success. She has made remarkable contributions to Indian cinema and has a career spanning nearly 16 years where she has demonstrated versatile acting skills and is extremely popular amongst the masses.
The defendants operate chatbot platforms and are owners of brands that are using Sonakshi Sinha’s likeness and various elements of her persona such as her voice, name and images for selling merchandise and imitating her likeness in order to make unjust commercial gains. Some of the images are most inappropriate and portray the Sonakshi Sinha wearing obscene clothing, thereby tarnishing her image and reputation.
The chatbot platforms of Defendants 1 and 2 are hosting multiple chatbots presenting the Sonakshi Sinha and imitating her likeness. Users can interact as if they were interacting with her. The chatbots allow users to interact with them to generate outputs which are in many cases obscene or otherwise objectionable. These platforms are private and for profit corporations that provide their users service for profit basis and Defendant 1 in particular has received significant venture capital and is clearly monetising the illegitimate, infringing and derogatory use of Sonakshi Sinha’s likeness including her name, image, voice and personality.
Analysis, Law and Decision
Upon perusal of the record, the Court noted that there was exploitation and unauthorised use of Sonakshi Sinha’s name, voice, image, likeness and other attributes of her persona, which was liable to be injuncted. Some of these infringers are also hosting images of Sonakshi Sinha with inappropriate clothing and obscene content using AI tools, which is causing irreparable damage to her reputation. As for images showing Sonakshi Sinha as a brand endorser of the merchandise, the additional concern is that if the goods turn out to be of inferior quality, it would be a further debasement of her goodwill and reputation.
The Court opined that the plaintiff had made out a prima facie case for grant of ex parte ad interim injunction. Balance of convenience lay in favour of the plaintiff and he is likely to suffer irreparable harm in case ex parte ad interim injunction as prayed for, is not granted.
Accordingly, the Court directed that —
1. Defendants 1 to 17, and all persons claiming through them or under them were restrained from publishing any material or manufacturing, selling or advertising any merchandise which violates the plaintiff’s publicity/personality rights by utilising and/or in any manner, directly or indirectly, the plaintiff’s:
(a) name “Sonakshi Sinha” and/or any abbreviation, moniker, title or variation thereof;
(b) voice;
(c) image;
(d) likeness;
(e) unique style of discourse and delivery; and
(f) any other attributes which are exclusively identifiable/associated with her,
for any commercial and/or personal gain, without the Sonakshi Sinha’s consent and/or authorisation in all formats and on all mediums, such as but not limited to AI-generated content, deepfake videos, voice-cloned audio, metaverse environments.
2. Defendants 1, 2, 4 to 17 were directed to disable, block or take down the infringing URLs mentioned in the plaint.
[Sonakshi Sinha v. Character Technologies Inc., 2026 SCC OnLine Del 1177, decided on 20-3-2026]
Advocates who appeared in this case:
For the Plaintiff: Anushka Sharda, Abhi Udai Singh Gautam, Advocates
For the Defendants: Mrinal Ojha, Debarshi Dutta, Arjun Mookerjee, Shivam Tiwari, Advocates