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Personality Rights in India

India has no dedicated statute protecting personality or publicity rights. What exists instead is a body of Delhi and Bombay High Court orders that have granted relief against unauthorised commercial or synthetic use of a person's name, image, voice or likeness. This page sets out what each of the leading cases actually decided, and why the area is still best understood as developing rather than settled.

No dedicated statute

Unlike defamation, copyright or trademark law, personality and publicity rights in India are not the subject of a specific Act of Parliament. Courts have instead extended a mix of common-law principles, the right to privacy recognised under Article 21, and elements of trademark and passing-off reasoning to protect a person's name, image, voice, signature and other identifying attributes against unauthorised commercial exploitation. Because the doctrine is judge-made and applied case by case, its boundaries move with each new order rather than being fixed by a single text. That makes precise, accurate reading of what each case actually held more important than usual — and more important than treating any one order as a general rule.

The leading cases, and what each one actually decided

Three orders currently do most of the work in this area. Their procedural status differs, and that difference matters.

Anil Kapoor v. Simply Life India & Ors.

Delhi High Court, decreed 30 April 2024. The court granted a permanent injunction protecting the actor's name, image, voice and other personality attributes, including against AI-generated and morphed misuse. This is a final decree, not an interim order — but it was granted against defendants who did not appear to contest the claim, which is a material qualification on how far it can be read as a tested precedent.

Jaikishan Kakubhai Saraf (Jackie Shroff) v. The Peppy Store & Ors.

Delhi High Court, order dated 15 May 2024. The court restrained unauthorised commercial use of the actor's name, image, voice and other personality attributes, including AI-based misuse. This is an interim order made at an early stage of the proceeding, not a final adjudication on the merits.

Arijit Singh v. Codible Ventures LLP

Bombay High Court, 26 July 2024, reported at 2024 SCC OnLine Bom 2445. The court granted relief against unauthorised AI-based cloning of the singer's voice. This is the clearest judicial engagement so far with AI voice cloning specifically, and, like the Jackie Shroff order, was granted at an interim stage of the proceeding.

Of the three, only the Anil Kapoor matter has reached a final decree. It should still be read narrowly: the relief was granted without a contesting defendant, so it has not been tested through adversarial argument in the way a fully contested final judgment would be.

A developing area, not settled law

It would overstate the current position to describe Indian personality rights as settled law. What exists is a consistent judicial willingness to grant injunctive relief — mostly interim — against unauthorised commercial or synthetic use of a person's identity, built up through individual High Court orders rather than through appellate consolidation or legislation. The Anil Kapoor decree is a notable final outcome, but it stands alongside, not above, an otherwise interim-relief-driven body of case law. Future orders, including any that involve a genuinely contested defendant, could refine or narrow how these principles are applied.

For agencies, brands and rights holders, the practical implication is the same regardless of how the doctrine eventually settles: a licence or release that does not expressly address AI-generated or synthetic use is not a substitute for it, and cannot safely be assumed to authorise it. See this site's likeness licensing page for what that drafting should cover. For individuals whose image, voice or likeness has been misused, see the deepfake and content removal page for the applicable takedown and reporting routes.

If you have received a notice or been named a defendant

Personality rights litigation in India increasingly proceeds against unidentified or newly-identified defendants through John Doe orders, and against named defendants through interim injunction applications. Being served with either raises questions that are procedural before they are substantive.

John Doe orders bind people who were never individually named

Where a court has granted relief against unidentified defendants, anyone subsequently identified as hosting, sharing or distributing the content in question can be bound by that order without a fresh hearing on the original application. Being added to such an order is not the same as having had an opportunity to contest the underlying claim, and the appropriate response depends on which stage the matter has reached.

Where an interim injunction application has been filed naming a specific defendant, the available responses include:

  • Contesting the interim application on the merits — including, where genuinely applicable, that the use falls within satire, parody, news reporting, criticism or another form of protected expression under Article 19(1)(a). As this site notes elsewhere, this defence has rarely been tested against a contesting defendant in the recent personality rights orders, which cuts both ways: the law is not settled against it either.
  • Seeking variation or vacation of an ex parte order where relief was granted without the defendant having been heard, which is the position in most of the reported cases discussed on this page.
  • Challenging the identification itself where a person has been added to a John Doe order on the basis of an IP address, account, or device that does not establish they were responsible for the conduct alleged.

Where the underlying conduct is also said to engage the criminal law — commonly Section 319 of the Bharatiya Nyaya Sanhita for personation, or provisions of the IT Act — the civil and criminal tracks proceed independently, and a response to one does not resolve the other. The criminal-side position, including bail and quashing, is addressed on this page.

On representation

A defendant in a personality rights matter, whether named or added to a John Doe order, is entitled to contest the claim and to be heard before relief is made final. Nothing on this page is a comment on the merits of any particular matter.

Law stated as at 11 August 2026

Frequently asked

Is there an Indian law specifically protecting personality or publicity rights?

No. There is no dedicated statute. Protection is built through individual Delhi and Bombay High Court orders drawing on privacy, passing-off and related common-law principles.

Is the Anil Kapoor case a final ruling on personality rights?

It is a final decree, decided 30 April 2024, granting a permanent injunction. It was granted against defendants who did not appear to contest the claim, which limits how far it can be treated as a fully tested precedent.

Are the Jackie Shroff and Arijit Singh orders final judgments?

No. Both are interim orders made at an early stage of their respective proceedings — the Jackie Shroff order on 15 May 2024 in the Delhi High Court, and the Arijit Singh order on 26 July 2024 in the Bombay High Court.

Has an Indian court specifically addressed AI voice cloning?

Yes. The Bombay High Court's order in Arijit Singh v. Codible Ventures LLP, reported at 2024 SCC OnLine Bom 2445, granted relief against unauthorised AI-based cloning of the singer's voice.

Can I rely on these cases as settled law for my own matter?

Treat them as evidence of a consistent judicial approach, not as settled law. Each order was made on its own facts, most at an interim stage, and the doctrine continues to develop.

I have been named in a John Doe order I never had a chance to contest. What can I do?

Being added to a John Doe order after the fact is not the same as having had an opportunity to argue the underlying claim. Where relief was granted ex parte, an application to vary or vacate the order is available, and is a different procedural step from applying to contest the original application from the outset.

I have received a legal notice claiming I misused someone's likeness. What happens next?

The notice itself, and any application it references, determine the timeline. Where an interim injunction has already been sought, a response is often required quickly. Where only a notice has been sent, there is generally more time to assess the position before an application is filed.

Can I argue that my use was parody, satire or commentary?

That defence exists under Article 19(1)(a) in principle, and this site notes elsewhere that it has rarely been tested against a defendant who actually contested a personality rights claim in the recent AI-related orders. The absence of a reported case rejecting the defence is not the same as an absence of merit, and whether it applies depends entirely on the facts of the use in question.

Does a civil claim affect a separate criminal complaint over the same conduct?

The two tracks proceed independently. A civil injunction application does not resolve a criminal complaint under the Bharatiya Nyaya Sanhita or the IT Act, and a criminal complaint does not resolve a civil claim. Each has its own procedure and its own timeline.

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