Delhi High Court: In a matter concerning the protection of the celebrity personality rights of actor and Member of Parliament Ravi Kishan against unauthorised online exploitation, a Single Judge Bench of Jyoti Singh, J., granted an ex parte ad interim injunction in his favour. The Court restrained the unauthorised use and commercial exploitation of Ravi Kishan’s name, image, likeness, voice, and other personality attributes. Recognising the increasing misuse of celebrity identities through artificial intelligence and digital platforms, the Court also directed the removal of objectionable online content, including AI-generated and deepfake material, holding that such acts were prima facie unlawful and likely to cause irreparable harm to Ravi Kishan’s reputation, dignity, and privacy.
Background
The plaintiff, Ravindra Shukla, popularly known as “Ravi Kishan”, is a celebrated actor, producer, and Member of Parliament with a career spanning more than three decades across Hindi, Bhojpuri, Telugu, Kannada, and Tamil cinema. He claimed that his name, image, likeness, voice, signature catchphrases, and other distinctive personality attributes have acquired immense goodwill, commercial value, and are protected as personality/publicity rights.
The suit was instituted against several individuals, online platforms, domain name registrars, and intermediaries alleging unauthorised commercial exploitation of his personality rights. According to Ravi Kishan:
1. Several defendants uploaded AI-generated, manipulated, defamatory, and obscene videos using his name, image, voice, and likeness.
2. Fake statements and fabricated political opinions were attributed to him on social media.
3. Multiple websites used his name as keywords and URLs to promote pornographic and sexually explicit content.
4. His image and persona were commercially exploited without authorisation, causing serious damage to his reputation, dignity, and goodwill.
He sought permanent injunction, removal of infringing content, and protection of his personality and publicity rights.
Issues
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Whether Ravi Kishan had established enforceable personality and publicity rights over his name, image, likeness, voice, and other identifiable attributes.
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Whether the defendants’ unauthorised use of these attributes, including through AI-generated content and pornographic material, amounted to infringement of the plaintiff’s personality rights.
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Whether Ravi Kishan was entitled to an ex parte ad interim injunction directing removal of the infringing content and restraining further misuse.
Analysis and Decision
The Court observed that Ravi Kishan enjoys immense reputation and goodwill earned through his distinguished career in cinema and public life. The Court noted that his name, image, likeness, voice, and other identifiable personality attributes possess significant commercial value and are entitled to legal protection. It reiterated that Indian courts have consistently recognised personality rights and protected celebrities against unauthorised commercial exploitation, relying on earlier Delhi High Court decisions which held that misuse of a celebrity’s persona not only causes commercial injury but also infringes their dignity and privacy.
The Court found that the unauthorised publication of obscene, pornographic, defamatory, and AI-generated content using Ravi Kishan’s identity was prima facie unlawful and likely to cause irreparable harm.
Holding that Ravi Kishan had established a strong prima facie case, that the balance of convenience lay in his favour, and that denial of interim relief would result in irreparable injury, the Court granted an ex parte ad interim injunction.
Accordingly, the Court restrained Defendants 1—20, Defendant 29, and all persons acting on their behalf from using, exploiting, or misappropriating Ravi Kishan’s personality rights, including his names “Ravindra Shukla” and “”Ravi Kishan”, image, likeness, voice, or any other distinctive attributes through any medium, including artificial intelligence (AI), generative AI, machine learning, deepfakes, social media, and virtual platforms. The defendants were further restrained from publishing any vulgar, obscene, pornographic, or otherwise offensive content using the plaintiff’s personality attributes.
The Court also directed the defendants operating websites and domain name registrars to remove the URLs within three days. In the event of non-compliance, Ravi Kishan was permitted to notify intermediary platforms, including Meta, Google, and X, which were directed to take down the identified content within 72 hours of receiving such intimation. Ravi Kishan was further directed to comply with the requirements of Order 39 Rule 3, Civil Procedure Code, 1908 within 2 weeks.
[Ravindra Shukla v. Ashok Kumar (John Doe), CS(COMM) 680/2026, decided on 2-7-2026]
Advocates who appeared in this case:
For Plaintiff: N. Hariharan and Sanjay Upadhyay, Senior Advocates, with Krishna Kumar Shukla, Neeraj Grover, Madhav Anand, Alvin Antony, Pranav Prasoon, Mansi Bachani, Kaulik Mitra, Kunal Khanna, Surya Pratap Singh, and Jitendra Bohra, Advocates.
For Defendants: Amee Rana, Radhika Roy, and Vishwajeet Deshmukh, Advocates for Defendant No. 30 (Meta Platforms Inc.); Rohan Ahuja, Shruttima Ehersa, and Ankit Tripathi, Advocates for Defendant No. 31 (Google LLC).
