Mehrab Consultants

Indian courts have categorized celebrities' images, voice, and personalty as valuable commodities and issued drastic injunctions against unauthorised advertising, deepfakes, and merchandise. This has been made possible through the guarantee of privacy under Article 21 of the Indian Constitution through judicial activism. The latest developments include celebrities fighting against the misuse of AI.

Judicial Roots of Protection

The principle of personality rights arose through cases related to privacy, not through laws. The Supreme Court decision of 1987 in the R. Rajagopal vs. State of Tamil Nadu case prohibited reproducing details about one’s personal life without consent, except when public records or official obligations require it. The Puttaswamy judgment by Justice Chandrachud in 2017 made privacy constitutional, allowing the protection of likenesses not harmed by commercial interests.

This was upheld by the Delhi High Court in the case of D.M. Entertainment & Anr. v. Baby Gift House (2010), as the mere mention of singer Daler Mehndi's name on toys led to "passing off." Today, the "likelihood of association" test has been applied by the courts to safeguard voice modulation, catch phrases, and gestures. Anil Kapoor's 2023 win has already stayed "morphed videos" copies of his "Ram Lakhan" character, as held by Justice Sanjiv Narula as "digital piracy" by common law principles.

Iconic Wins Shaping Precedent

Amitabh Bachchan led the way with broad relief about bans from the 2011 Delhi High Court for ads resembling his voice or his "Don" looks. Sellers incurred contempt of court for using voice-cloned promos, solidifying the notion that sound is intellectual property. A Bollywood movie, "Shadi Ke Director Karan Aur Johar" (2024), fell to the Bombay High Court because of a dilution of Karan Johar’s brand equity.

Award-winning Telugu actor Nagarjuna Akkineni won rapidement in September 2025, with the Delhi High Court compelling platforms to remove AI-generated nudes and deepfakes within 72 hours. Supreme Court Judge Amit Bansal cited the potential for irreparable harm from AI images spamming Telegram channels, prompting the use of keyword filters such as 'Nagarjuna deepfake.’

This applies to even the ecommerce sector, with the use of unauthorized mugs and tees prohibited. Hrithik Roshan’s previous lawsuit against lookalike emails exemplified the dangers of digital impersonations, with the courts investigating the traceability of AI software.

Live Courtroom Dramas Unfolding

Bhuvan Bam’s case on January 13, 2026, at the Delhi High Court revealed the judiciary’s restraint. The content creator demanded overall personality rights for morphed videos of BB Ki Vines in betting advertisements. Justice Jyoti Singh directed the deletion of the content via John Doe orders, but without prima facie relief, requiring the defendants to produce evidence regarding the commercials. Sites are required to delete over 50 URLs, but the case awaits an evaluation on the merit while replying to freedom of speech arguments.

The win in December 2025 represented aggressive expansion. As the Andhra Dy CM and “Power Star,” he filed suits against Flipkart, Amazon sellers, and AI firms for T-shirts, mugs, and deepfake rallies modeled on his speech style. The court order by Justice Pratibha M Singh required disclosures of KYC documentation from the seller, as he focused on generative networks that copied his walk and Telugu accent. E-commerce giants require everyday compliance reports, and contempt of court is pending for unremoved instances.

The Madras High Court intervened on January 11, 2026, for Kamal Haasan, providing relief to “John Doe” against voice cloning advertisements, although exceptions for satire are permitted. A anonymous party spoofed his “Vikram” vocal tone for loan scams; Justice Anand Venkatesh directed ISPs to block domains while permitting non-commercial spoofs

AI Deepfakes Fuel Urgent Rulings

The victory in the Nagarjuna case broke new ground in dismantling AI-specific cases, where the search for "AI Nagarjuna porn" was disabled on Google and Meta platforms. The judgment relied on Section 69(A) of the IT Act for platform accountability without notice. In Bhuvan’s case, Justice Singh hinted at the need for ‘clear statutory parameters’ in the wake of 500% deep-faked surges in 2025.

Balancing Act Amid Digital Risks

Judges balance the import of freedom of expression under Article 19(1)(a) with the guarantee of dignity under Article 21. Satire is allowed under the rubric of the law if it is not commercial, as seen when Haasan’s defense carved out a niche. The case will continue to favor the plaintiff because of the ease of proving the lack of likelihood of loss of goodwill through passing off San’s dilution.

Conclusion: Toward Statutory Clarity

The current legal scenario related to personality rights is reaching a point of importance. The year 2025 is seeing unprecedented activity by courts, granting to big names like Abhishek Bachchan, Karan Johar, and Asha Bhosle. The Bombay High Court’s clear mention of personality rights under Article 21 of the Constitution, as seen in the case of Sunil Shetty, is a huge milestone.

However, the lack of statutory codification is a concern nonetheless. In fact, definitions for "celebrity" or "personality rights" are currently absent in IP laws governing India, with significant matters left unresolved: the scope of liability regarding AIs, the term of posthumous rights, the duties of online platforms, and non-celebrity rights within the virtual realm

Author - Author- Rohan Verma (Intern January 2026)