On 18 September 2026, the Delhi High Court handed down an order that IP and media law practitioners across India have been discussing all week. In a suit filed by actor Meenakshi Chaudhary against unidentified defendants over non-consensual, sexually explicit AI-generated content bearing her likeness, Justice Anup Jairam Bhambhani granted an ex-parte ad-interim injunction directing takedown of the obscene material — but pointedly declined to grant the sweeping, “blanket” injunction her counsel had sought over all unauthorised uses of her image and persona. The order was reportedly passed alongside similar personality rights suits filed by other film actors, with the Court signalling an intent to lay down a more structured framework for how such claims should be evaluated going forward.
For a firm that regularly advises clients on brand protection, image rights and online enforcement, this order is a useful marker of where Indian courts currently stand on one of the fastest-growing categories of IP-adjacent litigation: personality and publicity rights in the age of generative AI and deepfakes.
What Are “Personality Rights” Under Indian Law?
India has no standalone statute recognising personality or publicity rights. What exists instead is a patchwork built up through judicial precedent, drawing on the tort of passing off, elements of copyright and trademark law (particularly where a celebrity’s name, image or signature phrase is used commercially without consent), the right to privacy read into Article 21 of the Constitution, and general principles against unjust enrichment and misappropriation. Over roughly the last decade, and especially since the mid-2020s, High Courts — the Delhi High Court in particular — have been asked with increasing frequency to grant injunctions protecting well-known individuals’ names, voices, images, mannerisms and even AI-cloned likenesses from unauthorised commercial exploitation, merchandising, and now, synthetic media.
Because there is no codified test, courts have had to develop their own working principles case by case. The Meenakshi Chaudhary order is the latest, and one of the more direct, judicial statements on how far such protection should extend.
The Core of the Ruling: A Line Between Categories of Harm
What makes this order significant is not that relief was granted — interim protection against non-consensual sexually explicit deepfakes is now fairly well established in Delhi High Court practice — but the reasoning the Court gave for what it refused to grant. Justice Bhambhani is reported to have stated that he was “against granting blanket injunctions” in personality rights matters, and pressed the plaintiff’s counsel on evidence: had the defendants actually monetised the impugned content, and if so, how was that being demonstrated? A rising view-count or the mere existence of unauthorised content, in the Court’s assessment, is not by itself proof of commercial exploitation.
Read together, the order appears to draw a distinction between at least two categories of impugned content:
- Sexually explicit, obscene, or otherwise degrading material generated without consent — which the Court was prepared to restrain on an ex-parte basis without extensive evidentiary scrutiny, given the nature of the harm; and
- Other, non-obscene uses of a public figure’s name, image or likeness — where the Court expects the plaintiff to make out a case of actual or likely commercial exploitation, rather than relying on a broad, open-ended injunction covering “all unauthorised use” in the abstract.
This is a meaningful development for defendants and intermediaries as well as for rights holders. Blanket “John Doe”-style injunctions covering an unspecified universe of future infringing content have been a recurring feature of Indian personality rights litigation, and have drawn criticism for being difficult to enforce precisely, prone to overreach, and in tension with free expression interests protected under Article 19(1)(a) — particularly where content involves parody, commentary, or fan tributes rather than commercial exploitation. A more calibrated, evidence-based approach, if it becomes the settled practice, would require plaintiffs to specify categories of content and demonstrate harm with greater particularity before wide-ranging relief is granted.
Why This Matters Beyond the Entertainment Industry
Although the immediate dispute involves a film actor, the underlying issue reaches well beyond entertainment law. Businesses increasingly use AI tools to generate marketing content, and the line between permissible creative use and unauthorised exploitation of a real person’s likeness is becoming harder to draw at scale. Company founders, doctors, financial advisors and other professionals whose credibility is part of their brand are also frequent targets of deepfake-driven scams — fabricated videos endorsing investment schemes or products they have never used. For businesses and individuals seeking to protect their own image or that of key personnel, this order is a reminder that Indian courts, while willing to act quickly against clearly obscene or harmful synthetic content, are likely to expect a more particularised showing of commercial harm before granting broader, standing protection.
It is also a reminder for brand owners and content platforms that the legal landscape here remains genuinely unsettled. Personality rights claims in India currently sit at the intersection of privacy law, tort, trademark and copyright principles, and IT intermediary rules, without a single, comprehensive statute to anchor them. Until Parliament or the higher judiciary provides a more codified framework, the contours of protection will likely continue to be shaped incrementally, order by order, as they were here.
Practical Takeaways
- If you are seeking protection against unauthorised use of your name, image, voice or likeness in India, be prepared to plead and evidence specific instances and categories of misuse, rather than seeking an omnibus injunction against all possible future use.
- Evidence of actual or likely commercial exploitation — monetisation, endorsement implication, use in advertising or merchandising — strengthens a claim considerably; mere existence of unauthorised content, without more, may not suffice for broader relief.
- Obscene, sexually explicit or clearly defamatory synthetic content continues to attract swift interim relief, and takedown requests in such cases should be pursued promptly, supported by clear documentation of the offending material and its source where identifiable.
- Businesses using AI-generated content in marketing or training materials should build in consent and clearance checks wherever a recognisable individual’s likeness, voice, or persona is involved, given the direction Indian courts appear to be taking on evidentiary standards for enforcement.
We expect this area of law to develop rapidly over the next few years as more such matters reach India’s courts, and will continue to track significant rulings as they are reported.
By Sevenelementz Legal Associates LLP, Advocates & IP Attorneys, Chennai.
Disclaimer: This article is intended for general informational purposes only and does not constitute legal advice. Laws and their interpretation may change, and individual circumstances vary. For advice specific to your situation, please consult Sevenelementz Legal Associates LLP or another qualified advocate.