Protecting Celebrity Personality Rights in the Age of AI: Insights from Hrithik Roshan Case

Introduction:

In an era where Artificial Intelligence can replicate faces, voices, and gestures with uncanny accuracy, the question of who owns a “digital self” has taken center stage. The Delhi High Court’s recent ruling in Hrithik Roshan v. Ashok Kumar (John Doe) & Ors. marks a significant moment in India’s evolving personality rights jurisprudence. The Court’s intervention ordering swift take-downs, data disclosures, and protection against AI-generated misuse signals how Indian law is adapting to the realities of deep-fakes, voice cloning, and the unauthorized monetization of celebrity identity.

Facts & Background:

Hrithik Roshan filed a commercial suit (CS(COMM) 1107/2025) before the Delhi High Court, seeking a permanent injunction against multiple online entities for misappropriating his personality and publicity rights.  The suit alleged that various websites, marketplaces, and apps were:

1. Using AI to clone Roshan’s voice, image, and likeness,
2. Creating vulgar and obscene deepfakes,
3. Selling unlicensed merchandise, and
4. Falsely associating his name with brands and domains.

The case named 33 defendants, including Google, Meta, Telegram, Amazon, Flipkart, and several “John Doe” (unknown) entities. Notably, the Plaintiff argued that these actions caused reputational damage and commercial loss by diluting his brand “HRX” and public image.

Key Issues Before the Court:

1. Whether a celebrity’s identity including name, image, voice, likeness, and AI-generated representations is protected under personality and publicity rights in India?
2. Whether the Court should grant an ex parte ad-interim injunction to prevent further misuse of Hrithik Roshan’s persona?
3. What obligations digital intermediaries and e-commerce platforms hold in removing infringing content and disclosing user details?
4. How to balance enforcement against fan expression and legitimate content?

Court’s Reasoning, Findings and Held:

The Delhi High Court recognized that Hrithik Roshan’s identity his name, image, likeness, and voice forms an integral part of his personality rights. The Court reaffirmed principles laid down in:

1. D.M. Entertainment v. Baby Gift House (2010),
2. Anil Kapoor v. Simply Life India (2023), and
3. Jackie Shroff v. The Peppy Store (2024).

The Court observed that the unauthorized commercial use of a celebrity’s persona amounts to:

1. Violation of publicity rights,
2. Infringement under the Copyright Act and Trade Marks Act and
3. Breach of privacy and goodwill.

Further, the Court noted the rising threat of AI-generated misappropriation including deepfakes, synthetic audio, and morphing which can cause irreversible harm to public figures. Therefore, the Delhi High Court granted an ex parte ad-interim injunction, restraining all defendants including John Doe entities from misusing Hrithik Roshan’s identity through AI, deepfakes, or similar tools. It ordered 72-hour takedowns of infringing content, domain suspensions, and disclosure of user details within three weeks, while ensuring fan pages and legitimate media were not unfairly removed.

Conclusion:

The Hrithik Roshan order is a landmark in India’s digital rights evolution bridging celebrity identity, technology regulation, and AI ethics. It showcases how traditional personality rights are being reshaped to address deepfake misuse and voice cloning in the social media age. Going forward, this judgment will serve as a reference point for protecting public figures from synthetic impersonation while ensuring platforms adopt faster, fairer, and more transparent content governance models.