Delhi High Court: In an interim application filed by actor Salman Khan seeking protection of his personality and publicity rights, a Single Judge Bench of Jyoti Singh, J., restrained the dissemination of the teaser and related promotional material of the proposed film “Kala Hiran — The Battle For Legacy”, holding that, prima facie, the defendants were commercially exploiting the plaintiff’s persona without his consent. Observing that the right to personality is an intrinsic facet of Article 21 of the Constitution encompassing the rights to privacy, dignity and reputation, the Court held that the impugned teaser and accompanying social media posts, which unmistakably alluded to the plaintiff and the pending blackbuck case against him, were prima facie gravely damaging to his goodwill and reputation and deserved to be taken down pending adjudication.
The present application arises from the release of the teaser of the proposed film “Kala Hiran — The Battle For Legacy” on 17 July 2026 across various digital and social media platforms. Notably, this was the second such teaser released by the defendants. The plaintiff-Salman Khan contended that the teaser, along with related promotional material, unlawfully associates the film with him by portraying a dramatised courtroom trial of a celebrated “superstar” accused of killing a blackbuck. Although the character is named “Ayan Khan”, the teaser allegedly contains unmistakable references to the plaintiff through dialogues invoking his iconic films Dabangg and Sikandar, references to Kankani Village and the Bishnoi community, and depictions mirroring the facts of the pending blackbuck case against him. According to the plaintiff, the teaser effectively pronounces him guilty despite the criminal proceedings remaining sub judice before the Supreme Court and the Rajasthan High Court, thereby prejudicing his defence.
The plaintiff further alleged that the defendants have undertaken a coordinated promotional campaign across platforms such as YouTube, Instagram and X by repeatedly using his name, identity and photographs to generate publicity and commercially exploit his personality without consent, in violation of his personality and publicity rights and in breach of the Delhi High Court’s earlier restraint order dated 11 December 2025. It is also alleged that several promotional posts and videos contain defamatory statements portraying the plaintiff as a criminal, linking him with the underworld and terrorist organisations, and encouraging public hostility against him. Contending that the teaser and related promotional material have caused irreparable harm to his reputation and goodwill while facilitating unauthorised commercial exploitation of his persona, the plaintiff seeks immediate restraint against the defendants from publishing or disseminating any content associating him with the proposed film.
The Court observed that the plaintiff-Salman Khan, being a well-known personality who has acquired celebrity status, has protectable personality rights, including his name, likeness, voice, image and other attributes of his persona, and no third party has a right to use or commercially exploit these attributes without his consent or authorisation. Prima facie, the impugned teaser and the accompanying posts on various social media platforms formed part of a promotional campaign to commercially exploit the plaintiff’s personality rights and public persona to generate commercial interest in the proposed film. The Court noted that the teaser, though referring to the accused as “Ayan Khan”, used expressions such as Dabangg and Sikandar, titles of the plaintiff’s commercially successful films, besides alluding to the alleged blackbuck killing and incorporating references to contested evidence forming part of the pending criminal proceedings. The Court also took note of the social media posts referring to the plaintiff as a “criminal”, alleging his enmity with the Bishnoi community, and linking him to the underworld and international terrorist organisations, holding that the cumulative narrative was prima facie irreparably and gravely damaging to the plaintiff’s formidable goodwill and reputation.
Reiterating that the right to personality has been recognised as an intrinsic facet of Article 21 of the Constitution, encompassing the rights to privacy, dignity and reputation, the Court held that the plaintiff has the right to determine the manner in which his persona is commercially exploited and that the proposed defendants cannot exploit his name, mannerisms and other distinctive attributes for commercial gains or publish and disseminate content injuring his reputation. The Court further observed that the use of social media to disseminate content violating personality rights or harming reputation exacerbates the mischief, given the speed, reach and permanence of digital publications, and has the potential to cause immediate and irreparable harm. Holding that the balance of convenience lay in favour of the plaintiff and that irreparable injury would ensue in the absence of interim protection, the Court held that the impugned teaser and the accompanying posts deserved to be taken down, subject to the final outcome of the application.
Accordingly, till next date of hearing:
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The Court restrained proposed Defendants 49—52, and all persons acting on their behalf, from exhibiting, streaming, broadcasting, uploading, hosting, sharing, publicising or otherwise disseminating the impugned teaser, accompanying posts/videos or any part thereof through any medium whatsoever, including social media platforms, video-sharing platforms, websites, OTT platforms, television and print media, till the next date of hearing.
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The Court directed proposed Defendants49—52 to take down the URLs under their control or operated at their instance, within 24 hours of receipt of the order.
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The Court further directed X (formerly Twitter), Meta Platforms Inc. and Google LLC to take down the respective URLs, if the uploaders failed to do so within the time granted by the Court. Necessary action was directed to be taken within 24 hours of receipt of information from the plaintiff.
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The Court directed the plaintiff to comply with the provisions of Order 39 Rule 3 Civil Procedure Code, 1908 within 2 days.
The matter is listed for hearing on 9 September 2026.
[Salman Khan v. Ashok Kumar, CS(COMM) 1322 of 2025, decided on 30-7-2026]
Advocates who appeared in this case:
For the Plaintiff: Ravi Prakash, Senior Advocate with Nizam Pasha, Parag Khandar, Chandrima Mitra, Krishan Kumar, Tapan Radkar, Zara Bhanbhoora, Sidharth Kaushik, Astu Khandelwal, Charu Sharma, Taha Yasin and Sarthak Seghal, Advocates
For the Defendant: Ajay Kumar, SPC, Manish Rawat, GP, Ankit Parhar, Tejpal Singh Rathore, Abhishek Kumar, Tanish Gupta, Sanchli Sethi, Varun Pathak, Radhika Roy, Nivedita Sudheer, Aditya Gupta, Asavari Jain, Akanksha Singh, Vishesh Oberoi, N.L. Ganapathi, Prabudh Singh Manas Raghuvanshi, Kuber Mahajan, Affan Moin, Binsy Susan, Palak Kaushal, Khushbu Turki, Pradyumn Sharma, Suvarna Singh, Pulkit Agarwal, Anubhav Lamba, Sudhanshu Kumar, Utkarsh Singh, Rajat Kumar, Shubham, Sudhanshu Kavshesh, Advocates