Delhi High Court Grants Interim Injunction Against AI-Generated Movie: Akira Nandan Vs. Sambhawaami Studios LLP & Ors.

Summary

The Delhi High Court, in Mr. Akira Desai alias Akira Nandan v. Sambhawaami Studios LLP & Ors., CS(COMM) 68/2026, intervened to protect the personality and privacy rights of Telugu actor Akira Desai, also known as Akira Nandan, after an AI-generated film and several deepfake videos used his name, likeness, and persona without consent. Viewing the matter as an urgent instance of digital exploitation, the Court granted an ex-parte ad interim injunction, restrained the release and circulation of the impugned AI film titled “AI LOVE STORY,” and directed the takedown of multiple infringing links on platforms including YouTube, Facebook, Instagram, and X that misused the Plaintiff’s identity.

Facts of the Case

The Plaintiff is a 21-year-old student from the Konidela family, a prominent film and political family in the Telugu industry. He enjoys considerable public recognition owing both to his lineage and his own artistic pursuits in music and cinema. He has appeared in the Marathi film “Ishq Wala Love,” contributed to the music of the Telugu film “OG,” and operates a YouTube channel titled “thechordfather,” which has a substantial following. In popular media and fan discourse, he is often referred to as “KONIDALA KID,” “POWER STAR KID,” “RISING STAR KID AKIRA,” and “PSPK STAR KID.”

Defendant No. 1 allegedly created a one-hour AI-generated film titled “AI LOVE STORY,” promoted as the “world’s first global AI movie,” featuring an AI-generated avatar of the Plaintiff in the lead role. The film was uploaded on YouTube through Defendant No. 2’s platform. In addition, several AI-morphed clips, including romantic and intimate scenes, fan-edited reels, and impersonation accounts, were circulated across YouTube, Meta platforms, and X. Many of these were reportedly monetised or used for crowdfunding in the Plaintiff’s name, without his consent.

Issues before the Court

The Court was essentially dealing with four core issues at the interim stage:

1. Whether the unauthorised use of the Plaintiff’s name, image, likeness, voice, and persona in an AI-generated film and related deepfake content constituted a violation of his personality and publicity rights?
2. Whether the creation and circulation of AI-generated and deepfake content, particularly intimate, romantic, or fabricated scenes, amounted to an infringement of the Plaintiff’s right to privacy, dignity, and reputation?
3. Whether the widespread dissemination and apparent commercial exploitation of such content, including through impersonation accounts and crowdfunding or donation pages, warranted the grant of an immediate ex-parte ad interim injunction?
4. To what extent the Court could, at the interim stage, direct intermediaries such as YouTube and Meta to remove the infringing content and disclose relevant account details and IP information associated with the offending uploads. 

Arguments

On behalf of the Plaintiff, learned senior counsel Mr. J. Sai Deepak, placed reliance on the Delhi High Court’s decision in DM Entertainment Pvt. Ltd. v. Baby Gift House to contend that personality and publicity rights are recognised under Indian common law and safeguard an individual’s name, image, likeness, and persona from unauthorised commercial exploitation. It was submitted that Defendant No. 1 had created an entire AI-generated film and related derivative content centred around the Plaintiff’s identity, using his face, likeness, and voice with such realism that the AI avatar appeared convincingly authentic. This, it was argued, amounted to clear misappropriation of the Plaintiff’s persona and created a false impression of endorsement or participation.

Counsel further drew the Court’s attention to certain AI-generated images and videos, including content suggesting fabricated romantic associations with a minor celebrity and crowdfunding posts on platforms such as Ketto, purportedly made in the Plaintiff’s name. These instances, it was contended, demonstrated not only infringement of personality rights but also posed a serious risk of deception and fraud upon unsuspecting fans. Relying on the recent interim order in R. Madhavan v. G Filmz Studioz & Ors., counsel urged the Court to grant urgent and stringent injunctive relief, including immediate takedown directions to intermediaries and disclosure of details pertaining to anonymous infringers responsible for the impugned content.

Decision of the Court

The Court held, prima facie, that the Plaintiff is a recognisable public personality with a distinct and commercially valuable image. It observed that the very decision to cast an AI avatar of the Plaintiff as the lead character in “AI LOVE STORY” demonstrated the commercial pull of his persona. The large-scale use of AI tools and deepfake technology to create realistic yet fabricated visuals and narratives around him, the Court noted, posed a serious risk of exploitation of his name, likeness, voice and identity, and had the potential to cause irreparable harm to his reputation and dignity.

Relying on DM Entertainment Pvt. Ltd. v. Baby Gift House, the Court reiterated that the right of publicity stems from an individual’s autonomy to control the commercial use of their identity. Any unauthorised commercial use that misleads the public or falsely suggests endorsement is impermissible. While acknowledging the importance of free speech, the Court clarified that the present case did not concern parody or satire, but rather monetised deepfake content and misleading portrayals, which clearly crossed the line into unlawful exploitation.

Accordingly, the Court:

• Restrained the Defendants and all persons acting on their behalf from creating, publishing, uploading, sharing or disseminating the impugned AI-generated film “AI LOVE STORY (Telugu) 4K” (in Telugu and English), or any related content using the Plaintiff’s personality traits on any platform, through any technology, including AI, generative AI, machine learning or deepfake tools.
• Further restrained the Defendants, including unknown “John Doe” parties, from using or misappropriating any facet of the Plaintiff’s personality, his name (“Akira”, “Akira Nandan”, “Akira Desai” or any variants), photographs, images, likeness, voice, speech patterns, mannerisms, signature poses, performances, dialogues, or any morphed/deepfake content, for commercial or personal gain without his express consent.
• Restrained them from distorting, modifying or manipulating his persona in a manner that violates his right to privacy or is prejudicial to his reputation, across both physical and virtual spaces, including websites, social media platforms, mobile applications and even the metaverse.
• Directed Meta (Defendant No. 3) to notify users responsible for the infringing URLs listed in Annexure A to remove the content within 72 hours. In the event of non-compliance, Meta was directed to take down the content itself and furnish basic subscriber information and IP login details of the concerned account holders to the Plaintiff within three weeks.

The Court concluded that the Plaintiff had established a strong prima facie case, that the balance of convenience lay in his favour, and that injury to his personality and public image was incapable of being adequately compensated in monetary terms.

In addition to the above directions, the Court observed that cases involving AI-generated and deepfake content raise evolving and complex concerns. It therefore requested Mr. J. Sai Deepak, learned senior counsel for the Plaintiff, along with Mr. Pathak and Mr. Gupta, learned counsel for Defendant Nos. 2 and 3 respectively, to assist the Court in formulating an appropriate procedural framework to be followed while adjudicating similar grievances in the future.

Conclusion/Analysis

This order marks a significant development in the manner in which Indian courts are responding to deepfakes and AI-driven misuse of identity, particularly in the entertainment industry. The Court treats personality rights, publicity rights, and privacy as dynamic and evolving doctrines, and extends their protection to AI avatars, synthetic voices, and deepfake visuals. In doing so, it sends a clear signal that the law will not remain static in the face of rapidly advancing technology.

From a practical standpoint, the order is equally notable for its robust directions to intermediaries. The Court did not confine itself to directing mere takedown; it imposed time-bound compliance requirements and mandated disclosure of basic subscriber and IP details. Such directions strengthen enforcement in an online environment where anonymity often shields wrongdoers.

At the same time, by invoking the cautionary observations in DM Entertainment regarding free speech and parody, the Court preserved space for legitimate artistic and creative expression. However, it drew a firm line where AI-generated content becomes commercial, misleading, or violative of privacy and dignity.

Overall, the case reflects the trajectory of Indian personality rights jurisprudence: towards recognising a broad and flexible protective shield over an individual’s digital persona, particularly where AI technologies are deployed to commodify identity without consent.