Personality Rights in the Digital Age: Delhi High Court Strengthens Protection Against AI Misuse and Unauthorized Commercial Exploitation

In April 2026, the Delhi High Court passed two significant interim orders that reaffirmed and expanded the protection available to personality rights in India. In separate actions instituted by businessman Dr. Sanjiv Goenka and actor Allu Arjun, the Court addressed unauthorized exploitation of personality attributes across a wide range of digital and AI-driven contexts.

Background: Two Landmark Interim Orders

Both decisions demonstrate the Court’s growing recognition that a celebrity or public figure’s identity—including their name, voice, likeness, gestures, persona, and other distinctive attributes—possesses independent commercial value deserving legal protection against unauthorized use.

This recognition is particularly important in the rapidly evolving digital and AI ecosystem, where technologies such as deepfakes, voice cloning, and generative AI make unauthorized exploitation easier than ever before.

Dr. Sanjiv Goenka v. Google LLC & Ors., CS(COMM) 395/2026

In the first matter, Dr. Sanjiv Goenka, Chairman of the RP-Sanjiv Goenka Group, approached the Delhi High Court seeking protection of his personality rights against several allegedly defamatory, disparaging, and AI-generated social media posts and video reels circulated across digital platforms.

The plaintiff asserted that his name, image, likeness, voice, and other facets of his persona had acquired substantial goodwill and commercial value through decades of business leadership, philanthropy, sports management, and public engagement.

Plaintiff’s Reputation and Personality Attributes

The Court noted the plaintiff’s immense public reputation, including his leadership of the multi-billion-dollar RPSG conglomerate, ownership of sports franchises such as Lucknow Super Giants and Mohun Bagan Super Giants, and extensive public recognition in business and philanthropic spheres.

The Court further observed that the plaintiff’s personality attributes had evolved into commercially valuable source identifiers uniquely associated with him.

AI-Generated Content and the Limits of Parody

A substantial portion of the dispute concerned AI-generated content, manipulated videos, fake narratives, and derogatory reels circulated online, many of which revolved around IPL-related content associated with the plaintiff’s sports franchises.

The Court distinguished legitimate parody and caricature from unlawful exploitation and observed that several impugned posts crossed the threshold of permissible expression and prima facie infringed the plaintiff’s personality rights.

While relying upon the landmark decision in D.M. Entertainment Pvt. Ltd. v. Baby Gift House, the Court reiterated that publicity rights protect the commercial value embedded in an individual’s persona and prevent unauthorized appropriation for commercial gain.

At the same time, the Court acknowledged that parody, caricature, and lampooning form part of protected free speech; however, content that is defamatory, misleading, or exploitative cannot seek shelter under artistic expression.

Injunctive Relief Granted

The Court granted an ex parte ad interim injunction restraining unauthorized use of Dr. Goenka’s name, image, likeness, and other identifiable personality attributes, including misuse through the following technologies:

• Artificial Intelligence and Generative AI
• Machine Learning
• Deepfakes
• AI Chatbots
• Face Morphing
• Superimposition techniques

The Court also directed intermediaries including Google, Meta, and X to take down infringing content and disclose basic subscriber information of the offending accounts.

Allu Arjun v. Frankly Retail Pvt. Ltd. & Ors., CS(COMM) 403/2026

In the second matter, actor Allu Arjun sought protection against unauthorized commercial exploitation of his name, persona, image, gestures, voice, dialogues, trademarks, and AI-generated content. The suit involved online merchandising, fake endorsements, sexually explicit content, AI-based voice cloning tools, and simulated interactions falsely associated with the actor.

Commercial Value of Distinctive Personality Traits

The Court extensively recorded the plaintiff’s stature as one of India’s most commercially successful actors, particularly following the pan-India success of the Pushpa franchise. It took note of the plaintiff’s distinctive personality traits, including:

• Iconic dialogues
• Gestures such as the “Thaggede Le” hand movement
• Unique mannerisms and dance style
• Appearance and vocal delivery

All of these had acquired immense commercial value and public association.

The Court further acknowledged that the plaintiff had proactively secured trademark registrations over his name and associated marks under the Trade Marks Act, 1999, thereby reinforcing the proprietary nature of his personality attributes.

The Court held that the plaintiff’s name, likeness, gestures, speech, performances, signature style, and other identifiable characteristics functioned as source identifiers and were entitled to legal protection against unauthorized exploitation.

AI-Related Infringements

Particularly significant was the Court’s recognition of emerging AI-related infringements. The allegations included AI-generated voice cloning tools, deepfake content, simulated “fake calls,” and unauthorized digital recreations of the actor’s identity.

The Court observed that such technologies could substantially harm the plaintiff’s goodwill, reputation, and commercial interests.

Scope of Injunction

The Court passed a broad injunction restraining the defendants from exploiting the plaintiff’s personality rights, moral rights, registered trademarks, performances, and associated persona through any medium, including:

• Websites and social media platforms
• Metaverse environments
• AI tools and Generative AI systems
• Machine Learning technologies
• Deepfakes and Face Morphing technologies

The Court also directed intermediaries to remove infringing links and online content.

Emerging Trends in Personality Rights Jurisprudence

Taken together, both orders represent an important evolution in Indian personality rights jurisprudence. Traditionally, Indian courts have recognised publicity rights primarily in the context of celebrity endorsements, merchandising, and commercial appropriation.

However, these decisions indicate a clear judicial expansion of personality rights into the realm of AI-generated identities, digital avatars, voice cloning, manipulated media, and synthetic content.

The Delhi High Court’s approach demonstrates increasing judicial willingness to treat personality attributes as commercially protectable intellectual assets capable of enforcement across both physical and digital environments. Importantly, the Court recognized that personality rights are not confined merely to names and photographs but extend to:

• Gestures and voice
• Mannerisms and performances
• Dialogue delivery and appearance
• Digital recreations and other uniquely identifiable traits associated with an individual

The decisions also reflect judicial concern regarding the misuse of generative AI technologies and deepfake systems capable of fabricating realistic but unauthorized representations of public figures.

By expressly including AI tools, machine learning systems, deepfakes, and virtual environments within the scope of injunctive relief, the Court has effectively acknowledged the transformative legal challenges posed by artificial intelligence to reputation, identity, and commercial personality rights.

Conclusion

The Dr. Sanjiv Goenka and Allu Arjun orders mark a significant strengthening of personality rights protection in India. Both decisions reinforce that public figures possess enforceable proprietary and reputational interests in their persona, identity, and commercially valuable attributes.

More importantly, these cases signify a decisive judicial response to the misuse of AI technologies, deepfakes, voice cloning systems, and unauthorized digital recreations. As artificial intelligence increasingly blurs the boundaries between reality and synthetic representation, Indian courts appear prepared to expand traditional publicity rights principles to address emerging forms of digital identity exploitation.

These rulings are likely to serve as important precedents in future disputes involving celebrity rights, AI-generated content, online impersonation, and virtual commercial exploitation in India’s rapidly evolving digital ecosystem.