Brief Introductory Head Note Summary of the Case
This matter arises from a suit filed by renowned Bollywood actor Ajay alias Vishal Veeru Devgan seeking protection of his personality rights, publicity rights, trademark rights and reputation against various parties involved in impersonation, unauthorized commercial use of his name and image, sale of merchandise, creation and circulation of AI-generated deepfake videos, face-morphed photographs and obscene pornographic content falsely depicting him. The Delhi High Court, vide order dated 27 November 2025 passed by Hon’ble Ms. Justice Manmeet Pritam Singh Arora in CS(COMM) 1269/2025, granted a detailed ex-parte interim injunction, issued wide-ranging takedown and blocking directions, and clarified the obligations of social media intermediaries, government authorities and online sellers while dealing with misuse of celebrity identity and harmful AI-generated content. The Court also emphasized the importance of the statutory grievance redressal mechanism under the IT Rules for swift action.
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Factual Background
Ajay Devgn is one of India’s most celebrated actors with a career spanning over four decades. His performances, awards such as the Padma Shri, and presence as director and producer have created an extraordinary goodwill attached to his name, appearance and voice. His stage name and its variations are registered trademarks in multiple classes. He also commands a very strong digital presence through millions of followers on Instagram, Facebook and other platforms. This popularity and distinct identity make him a commercially valuable personality whose attributes cannot be used without authorization.
The plaintiff discovered that several entities were misusing his identity in different ways. Some were selling posters, hoodies, stickers, caps and other merchandise carrying his name and image without permission. Others were impersonating him or falsely advertising that he could be booked through their websites. More seriously, multiple social media accounts were posting AI-generated deepfake photographs and videos showing him in disrespectful, obscene or pornographic situations with female celebrities. Several unknown persons and pornographic websites carried explicit morphed content falsely depicting him. He argued that these acts not only violated his legal rights but also damaged his dignity, reputation and public image.
Due to these widespread infringements across different platforms, the plaintiff approached the Delhi High Court seeking immediate injunctive protection and orders directing removal and blocking of the infringing content.
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Procedural Details
Multiple interlocutory applications accompanied the main suit. The Court allowed exemption from notice to government defendants under Section 80(2) CPC as they were proforma parties. It also granted additional time for furnishing certain statutory certificates under the Bharatiya Sakshya Adhiniyam. Further, the Court exempted the plaintiff from pre-institution mediation under Section 12A of the Commercial Courts Act as the matter required urgent interim relief, relying on the Supreme Court’s decision in Yamini Manohar v. T.K.D. Keerthi (2024) 5 SCC 815.
The Court directed issuance of summons to all infringing defendants (Defendants 1, 2, 6, 8, 9, 10 and 11) and to YouTube/Google (Defendant 7), while treating several entities like Meta, X Corp., MeitY, DoT and others as proforma defendants for ensuring compliance with blocking and takedown directions.
Thereafter, the Court proceeded to hear the application for ex-parte interim injunction under Order XXXIX Rules 1 & 2 CPC.
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Core Dispute
The central dispute concerns whether the defendants, through unauthorized commercial activities, AI-generated deepfake content, obscene morphed images, impersonation and sale of merchandise, violated the plaintiff’s personality rights, publicity rights, trademark rights and reputation.
Another major issue is the responsibility of social media platforms and government authorities in controlling and removing harmful AI-generated content, and whether immediate court intervention was warranted when statutory grievance mechanisms under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 already exist.
The dispute therefore touches upon multiple overlapping areas of law, including:
Personality and publicity rights under Articles 19 and 21 of the Constitution
Statutory trademark protection under the Trade Marks Act, 1999
Performers’ and moral rights under Sections 38, 38A and 38B of the Copyright Act, 1957
Common law doctrines of passing off, unfair competition and misappropriation
Obligations of intermediaries under the IT Act and IT Rules
Regulation of deepfakes and non-consensual explicit content through emerging technological frameworks
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Detailed Reasoning and Discussion by the Court
The Court began by observing that Ajay Devgn is unquestionably a celebrity with enormous recognition and goodwill. It noted that his persona, including his name, image, likeness and voice, had acquired distinctiveness and commercial value due to a long and illustrious career. These attributes therefore deserved legal protection.
Recognition of Personality Rights
The Court relied upon three earlier decisions:
1. D.M. Entertainment v. Baby Gift House, MANU/DE/2043/2010
2. Anil Kapoor v. Simply Life India (2023 SCC OnLine Del 6914)
3. Jaikishan Kaku Bhai Sarf alias Jackie Shroff v. The Peppy Store (2024 SCC OnLine Del 3664)
These cases firmly establish that a celebrity’s personality traits—name, image, likeness and voice—are protectable under Indian law. Unauthorized use for commercial gain amounts to violation of personality rights.
Based on these precedents, the Court held that the plaintiff’s personality rights were prima facie infringed by Defendants who were selling merchandise or impersonating him.
Protection Against Deepfakes and Harmful AI Content
The Court expressed strong concern about AI-generated deepfakes that portray a celebrity in compromising, obscene or humiliating scenarios. Such content can seriously harm reputation and dignity. It held that the plaintiff was entitled to prevent the making, circulation and monetisation of such content, whether posted by identified or anonymous users.
The Court classified infringing content into categories:
Unauthorized merchandise
Impersonation and false association
AI-generated deepfakes
Face-morphed images
Explicit and pornographic morphed content
It held that all these harmed the plaintiff’s rights and required immediate intervention.
Role of Intermediaries and Statutory Mechanisms
The Court examined the duties of intermediaries like YouTube, Facebook, Instagram and X Corp. under the IT Rules. It noted that Rule 3(2) requires removal of non-consensual intimate content within 24 hours of complaint. It criticized the trend of directly approaching courts without first using the statutory grievance mechanism, emphasizing that such mechanisms were designed to provide faster relief and reduce judicial burden.
The Court clarified that if complainants bypass the statutory mechanism in future, they may not receive urgent ex-parte relief unless they first approach the intermediary’s grievance officer.
Directions for Take Down and Blocking
Despite cautioning against bypassing the IT Rules, the Court granted protection in this case due to the serious nature of the content and the urgency of preventing further harm. It issued sweeping injunctions restraining the defendants from:
Using the plaintiff’s name, image, voice, likeness
Creating or circulating deepfake or face-morphed content
Monetizing content generated using AI models trained on plaintiff’s images
Selling merchandise bearing his persona
The Court directed:
Immediate removal of infringing URLs within 72 hours
Delisting of infringing merchandise
Blocking of pornographic websites through MeitY and DoT
Provision of Basic Subscriber Information (BSI) of unknown infringers
Suspension of domain names hosting impersonation pages
Takedown of infringing content by YouTube, Meta, X Corp. and others
The Court imposed a coordinated compliance mechanism, requiring intermediaries and government departments to work together and respond to plaintiff’s future takedown requests within strict timelines.
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Decision
The Delhi High Court granted a detailed and far-reaching ex-parte ad-interim injunction in favour of Ajay Devgn. It restrained all infringing defendants and unknown persons from misusing the plaintiff’s personality attributes in any manner, including through AI-generated deepfake videos and morphed images. The Court directed takedown, delisting and blocking of infringing content and websites. It also laid down important future guidelines, emphasizing the mandatory use of the IT Rules grievance mechanism before seeking judicial intervention, and required intermediaries like X Corp. to establish proper representation and communication channels for advance service in such cases.
This order reinforces judicial intolerance towards misuse of celebrity identity, defamation through new technologies like AI, and exploitation of personality rights without authorization.
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Concluding Note
This case represents one of the most comprehensive judicial interventions in India on misuse of celebrity identity in the context of emerging technologies such as generative AI and deepfakes. It demonstrates the Court’s recognition of the increasing threat posed by manipulated digital content and its ability to cause irreversible harm to individual dignity and reputation. The judgment strikes a balance between strong protection of personality rights and encouraging responsible use of statutory grievance redressal mechanisms under the IT Rules.
The Court has sent a clear message that identity misappropriation, unauthorized commercial exploitation and circulation of AI-generated explicit content are serious violations that will invite strong judicial response. At the same time, it has clarified that intermediaries must maintain transparent communication channels and comply swiftly with takedown directions. This order therefore contributes to the evolving body of Indian jurisprudence on digital rights, celebrity protection, online safety, and regulation of AI-generated content.
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Case Details
Case Title: Ajay alias Vishal Veeru Devgan v. The Artists Planet & Ors.
Order Date: 27 November 2025
Case Number: CS(COMM) 1269/2025
Neutral Citation: 2025:DHC:____
Court: High Court of Delhi at New Delhi
Hon’ble Judge: Ms. Justice Manmeet Pritam Singh Arora
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Disclaimer and Author Note
Disclaimer: The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
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Suggested Titles for the Research Paper
1. Protecting Celebrity Identity in the Age of AI: A Study of Ajay Devgan v. The Artists Planet
2. Deepfakes, Personality Rights and Judicial Protection: An Analysis of the Delhi High Court’s 2025 Order
3. Digital Misuse of Celebrity Persona: Comprehensive Legal Insight from Ajay Devgan’s Case
4. AI-Generated Harm and Personality Rights Enforcement: Emerging Principles from Indian Courts
5. From Deepfakes to Domain Blocking: A New Framework for Protecting Celebrity Rights in India
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In Ajay alias Vishal Veeru Devgan v. The Artists Planet & Ors., CS(COMM) 1269/2025, decided on 27 November 2025 by Hon’ble Ms. Justice Manmeet Pritam Singh Arora of the High Court of Delhi, the Court granted an extensive ex-parte interim injunction protecting the personality and publicity rights of actor Ajay Devgan. The order was passed in response to widespread misuse of the actor’s name, image, likeness, and persona across multiple online platforms.
The Court noted that the plaintiff is a veteran and widely recognized film personality whose name, appearance, and voice possess significant goodwill and commercial value. The suit highlighted various infringing acts by several defendants, including impersonation, unauthorized sale of merchandise bearing his name and photographs, creation and circulation of AI-generated deepfake videos, morphed images depicting him with other celebrities, and pornographic content falsely showing him in obscene situations. Many online platforms and unknown entities hosted or facilitated dissemination of the infringing material.
After examining the evidence, the Court held that the plaintiff has a prima facie case for protection under personality rights, trademark law, performers’ rights, and common law doctrines such as passing off and misappropriation. Citing earlier decisions, including D.M. Entertainment v. Baby Gift House, Anil Kapoor v. Simply Life India, and Jackie Shroff v. The Peppy Store, the Court confirmed that a celebrity’s identity traits are protectable, and unauthorized commercial or reputational misuse warrants judicial restraint.
The Court issued directions restraining defendants from using the plaintiff’s name, likeness, or image in any form, including deepfake technology, face-morphing, AI tools, or commercial merchandise. It ordered immediate takedown of infringing links across YouTube, Facebook, Instagram, X Corp., and various e-commerce platforms. It also directed government authorities such as MeitY and DoT to block pornographic websites hosting morphed content and required intermediaries to provide Basic Subscriber Information of unknown infringers. The Court further observed that plaintiffs must ordinarily use the statutory grievance redressal mechanism under the IT Rules before seeking ex-parte judicial relief but granted protection in this case due to the seriousness of the harm.
This order is a significant step in strengthening legal safeguards against deepfakes, online impersonation, and misuse of celebrity identity in the digital age.
Disclaimer: This is for general information only and should not be construed as legal advice as it may contain human errors in perception and presentation: Advocate Ajay Amitabh Suman, IP Adjutor (Patent & Trademark Attorney), High Court of Delhi.
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