Delhi High Court: In a suit seeking protection of personality and publicity rights, filed by Telugu film actor and entrepreneur Akkineni Naga Chaitanya against the unauthorised commercial exploitation of his name, image, likeness and persona, including their use in pornographic content, artificial intelligence (AI)-generated and deepfake material, and unauthorised merchandise, a Single Judge Bench of Jyoti Singh, J., granted an ex parte ad interim injunction restraining the defendants from using or exploiting the plaintiff’s personality attributes for commercial or personal gain.
The Court held that the plaintiff had established a prima facie case, that the balance of convenience lay in his favour, and that continued dissemination of the impugned content and sale of infringing merchandise would cause irreparable harm to his reputation, goodwill and commercial interests.
Background
The plaintiff-Akkineni Naga Chaitanya, a prominent Telugu film actor and entrepreneur, instituted the present suit seeking protection of his personality and publicity rights against the unauthorised commercial exploitation of his name, image, likeness and persona. The plaintiff asserted that, having established a successful acting career spanning over 15 years and having acquired immense goodwill, reputation and celebrity status through his films, entrepreneurial ventures and public engagements, his name and persona have become valuable commercial assets associated with his identity.
According to the plaint, several defendants were operating websites and online platforms that were unlawfully using the plaintiff’s name, image and likeness without authorisation. Certain defendants allegedly hosted pornographic content and used the plaintiff’s name as a category, tag or trending label, thereby creating a false and objectionable association between the plaintiff and obscene material. It was further alleged that some defendants were selling merchandise bearing the plaintiff’s name, photographs and likeness without his consent, misleading consumers into believing that such products were endorsed by or affiliated with him. The plaintiff also alleged that online platforms were hosting videos and content, including AI-generated and deepfake material, which infringed his personality and publicity rights and caused reputational harm.
The plaintiff contended that the unauthorised use of his identity amounted to misappropriation of his personality rights and was causing serious injury to his goodwill, reputation and commercial value. It was submitted that the continued dissemination of such content and sale of unauthorised merchandise would result in irreparable harm to the plaintiff. Consequently, the plaintiff sought injunctive relief against the defendants, including unidentified John Doe entities, to restrain them from further exploiting his name, image, likeness and persona through pornographic content, defamatory material, deepfakes and unauthorised commercial merchandise.
Analysis
Upon hearing the plaintiff and perusing the material on record, the Court held that the plaintiff had made out a prima facie case for grant of an ex parte ad interim injunction. The balance of convenience was found to be in favour of the plaintiff and irreparable harm was likely to be caused if the relief sought was not granted. The Court observed that the plaintiff is unquestionably a renowned actor in the Indian film industry with an illustrious career spanning over 15 years, having earned substantial goodwill, reputation and public recognition through his work in Telugu and Hindi cinema.
The Court noted that Defendants 6, 7 and 11 were unlawfully selling merchandise bearing the plaintiff’s name, image and likeness without authorisation, thereby creating a false impression of endorsement or affiliation and commercially exploiting the plaintiff’s persona. Relying on Anil Kapoor v. Simply Life India, 2023 SCC Online Del 6914, the Court reiterated that a celebrity’s endorsement rights constitute a valuable source of livelihood and cannot be diluted through unauthorised sale of merchandise. The Court further observed that the plaintiff was entitled to protect his name, image, voice, likeness and other attributes of his persona from unauthorised use. Referring to Jaikishan Kakubhai Saraf v. Peppy Store, (2024) 2 HCC (Del) 253, and Aishwarya Rai Bachchan v. Aishwaryaworld.com, 2025 SCC OnLine Del 5943 the Court held that unauthorised use of a celebrity’s attributes causes not only commercial detriment but also affects personality and privacy rights.
The Court also recognised the plaintiff’s right to seek protection against dissemination of pornographic content, AI-generated images and deepfakes portraying him in inappropriate scenarios, observing that such content is harmful to his reputation and may mislead the public.
Decision
Consequently, the Court restrained the defendants from using or exploiting the plaintiff’s name, image, voice, likeness and other personality attributes for any commercial or personal gain, including through AI, generative AI, machine learning, deepfakes, AI chatbots, Face Morphing and/or any other mediums and formats. The Court further restrained the sale of infringing merchandise, directed removal of specified infringing URLs and directed the defendants concerned to take down the offending content within 24 hours of receipt of the order.
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[Akkineni Naga Chaitanya v. www.sexvid.xxx, CS(COMM) 644 of 2026, decided on 29-5-2026]
Advocates who appeared in this case:
For the Plaintiff: Vaibhav Gaggar, Senior Advocate with Somdev Tiwari, Akashdeep Gupta, Siddarth C., Abhishek Nair and Vansh Srivastav, Advocates.
For the Defendants: Mamta Rani Jha, Rohan Ahuja, Shruttima Ehersa and Sanya Sehgal, Advocates
