Background
This case concerns the unauthorized use of the name and personality attributes of film director Karan Johar in a film titled Shaadi Ke Director Karan Aur Johar. The film was co-produced by appellant Sanjay and was scheduled for theatrical release on 14 June 2024. On discovering the film’s trailer, Karan Johar filed a commercial intellectual property suit alleging infringement of his personality and publicity rights.
Relief Sought by Plaintiff
Karan Johar sought an injunction restraining the defendants from using his name or any related attributes in the film’s title, promotional materials, or public communications. He argued that the film was attempting to commercially exploit his brand, goodwill, and reputation without consent.
Arguments by Appellant
Sanjay argued that the film was fictional and that the characters “Karan” and “Johar” were common names not uniquely associated with Karan Johar. He contended there was no reference to Karan Johar personally, and that CBFC certification and pre-existing title registration legitimized the film. He further emphasized the financial loss due to last-minute injunctive relief and stated that the disclaimer clarified there was no connection with Karan Johar.
Court’s Findings
The Bombay High Court held that Karan Johar, as a widely recognized personality and brand, enjoys protectable personality and publicity rights. The title Shaadi Ke Director Karan Aur Johar clearly evoked a reference to the respondent, who is famously associated with films themed around grand weddings. The Court observed that even if the characters were fictional, the juxtaposition of name and profession created a direct connection to Karan Johar in public perception. The use was not incidental but a calculated attempt to ride on his fame. CBFC certification did not preclude legal scrutiny under personality rights.
Decision
The Court upheld the Single Judge’s order granting interim injunction. It restrained the defendants from using the name “Karan Johar” or any related identifiers in the title or promotions of the film. The appeal was dismissed, affirming that celebrities have enforceable rights against unauthorized commercial exploitation of their identity.
Sanjay Vs Karan Johar & Ors.:7 May 2025:Commercial Appeal (L) No. 9786 of 2025:2025:BHC-OS:7666-DB:High Court of Bombay:Hon'ble Chief Justice Alok Aradhe and M.S. Karnik
