Delhi High Court Grants Interim Protection To Pawan Kalyan Against AI-Generated Deepfakes And Unauthorised Commercial Use Of Personality Rights

Background and Nature of the Dispute

The Delhi High Court on 22 December granted extensive interim protection to actor and Deputy Chief Minister of Andhra Pradesh, Konidala Pawan Kalyan, against the unauthorised commercial exploitation of his personality rights through AI-generated content, deepfake, and online merchandise. The order was passed by Justice Manmeet Pritam Singh Arora in a suit filed by the actor against multiple e-commerce platforms, social media intermediaries, websites, and unidentified entities operating under the name Ashok Kumar/John Doe.

Allegations of Misuse of Personality Attributes Through AI and Online Platforms

Pawan Kalyan approached the Court alleging that his name, image, likeness, voice, and other personality attributes were being misused without consent for commercial gain. The plaint highlighted that AI-generated images and videos impersonating him were being circulated on platforms such as YouTube and Instagram. While merchandise bearing his likeness was being sold on e-commerce platforms, including Amazon, Flipkart and Meesho, etc. It was further alleged that several AI-based websites enabled users to generate synthetic images, videos, and voice replicas of the plaintiff, facilitating widespread infringement of his personality rights.

The actor was represented by Senior Advocate J. Sai Deepak, who submitted that the unauthorised use of the plaintiff’s persona was misleading the public, diluting his goodwill, and resulting in unjust benefit to third parties. It was argued that the plaintiff has built an immense reputation and commercial value over nearly three decades in cinema and public life, and that his identity constitutes a proprietary right deserving legal protection.

Judicial Recognition of Celebrity Personality and Publicity Rights

Justice Arora noted that the plaintiff is an established public figure whose name, image, likeness and voice are distinctly associated with him. Relying on a consistent line of Delhi High Court precedents, including DM Entertainment Pvt. Ltd. v. Baby Gift House, Anil Kapoor v. Simply Life India, and Jackie Shroff v. The Peppy Store, the Court reiterated that celebrity status gives rise to enforceable personality and publicity rights, particularly when such attributes are exploited for commercial purposes without consent.

Grant of Interim Injunction and Scope of Restraint

Upon examining the material on record, the Court found that the balance of convenience favoured the plaintiff and that irreparable harm would be caused if interim relief was not granted. Consequently, the Court restrained all identified defendants as well as John Doe entities from using, reproducing, publishing, or exploiting the plaintiff’s name, image, likeness, voice or persona for commercial purposes. This included infringement through artificial intelligence tools, deepfakes, and generative AI technologies.

Directions to E-Commerce Platforms and AI-Based Websites

The Court directed e-commerce platforms to take down infringing listings and delist merchandise using the plaintiff’s personality attributes. These platforms were also directed to disclose the complete KYC details of sellers found to be offering such infringing products. AI-based websites were restrained from enabling the generation of synthetic content using the plaintiff’s identity or voice.

Fan Pages and Non-Commercial Use

With respect to certain fan pages operating on Instagram, the Court adopted a nuanced approach. Justice Arora noted that while the content did involve the plaintiff’s likeness, it was neither derogatory nor demonstrably commercial in nature. Accordingly, the Court declined to grant an immediate takedown of such content at the interim stage. However, it directed that fan pages must prominently display disclaimers clarifying that they are not official accounts and that the content is not endorsed by the plaintiff. Failure to comply with this requirement would entitle the platforms to deactivate such accounts.

Directions to Intermediaries Under IT Rules

The Court further directed intermediaries such as Google and Meta to furnish basic subscriber details and IP login information pertaining to the remaining infringing URLs, in accordance with law. In line with earlier personality rights orders passed by the same Bench, the Court also directed the intermediaries to treat the plaint as a formal complaint under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and to act upon it within the stipulated time.

Justice Arora clarified that any third party who believes that lawful content has been affected by the order may approach the Court for appropriate modification, subject to furnishing an undertaking not to use the plaintiff’s personality attributes in an infringing manner. The matter has been listed for further hearing and compliance in May 2026.

Significance of the Order

The order adds to the growing body of jurisprudence from the Delhi High Court addressing the challenges posed by AI-driven impersonation, deepfakes, and unauthorised digital merchandising, reinforcing judicial protection of personality rights while balancing intermediary obligations and freedom of expression.