The Delhi High Court heard actor R Madhavan’s plea against AI-generated deepfakes, fake movie trailers, and unauthorised merchandise misusing his likeness online. The Court questioned selective content takedowns and directed removal of obscene material while keeping the AI issue open for further consideration.
New Delhi: The Delhi High Court is hearing a lawsuit filed by well-known actor R. Madhavan seeking protection of his personality rights against the misuse of his name, image, and likeness through artificial intelligence (AI) generated and deepfake content circulated online for commercial purposes.
The case is being heard by Justice Manmeet Pritam Singh Arora.
Senior Advocate Swathi Sukumar, appearing for Madhavan, informed the Court that several online platforms are hosting AI-generated videos, deepfake visuals, and fake movie trailers using the actor’s likeness without his consent.
One such example highlighted before the Court was a fabricated trailer of a non-existent film titled “Kesari 3”. It was submitted that while some of this content had been removed following complaints, platforms like YouTube refused to take down certain videos, claiming there was no copyright violation involved.
The Court raised serious concerns over the selective removal of content and questioned why some videos were taken down while other similar videos continued to remain accessible.
The Court also noted that obscene material using Madhavan’s image had been brought on record and further observed that unauthorised merchandise was being sold using the actor’s personality rights without his permission.
During the hearing, it was also informed that Meta had failed to remove several links that were flagged. On this issue, the counsel appearing for Meta sought a passover to examine the matter.
Arguing on behalf of the actor, Senior Advocate Swathi Sukumar stated,
“This is a commercial enterprise, not a fan page. I have a right over my likeness. They are using my name in hashtags, and there is no rational basis for taking down some links while leaving others.”
Responding to this, Meta argued that the content in question consisted of fan-created material. Meta submitted,
“These are fan pages, showing pairings people would like to see. The URLs also carry disclaimers stating the content is fake.”
Countering this defence, Sukumar strongly opposed the fan-page argument and clarified,
“This is far from a fan page. It is commercial and uses AI-generated compilations placing actors in situations they would never be in. Films like Shaitan Chapter 2 and Kesari 3 do not even exist. I have not lent my name or likeness to any such content.”
YouTube, while responding to allegations regarding one of the videos, submitted,
“The Shaitan Chapter 2 video is a compilation of the actor’s earlier films.”
Rejecting this explanation, Sukumar asserted the legal position of personality rights and told the Court,
“A person is asserting legally recognised rights over his likeness. Parody or fan-page defences cannot apply here.”
After hearing the arguments, the Court indicated its inclination to intervene and remarked,
“We will ask that such content be made invisible.”
However, Meta continued to maintain that the content was harmless and creative in nature. Representing Meta, counsel Varun Pathak submitted,
“This is benign memes and creative fan content. Someone may want to see Madhavan as Hulk.”
Responding sharply, Sukumar highlighted the commercial scale and public reach of the pages involved and stated,
“The page has thousands of followers. If it is taken down, a genuine fan would not object.”
After considering the submissions, the Court passed limited directions at this stage. It ordered that obscene material and unauthorised merchandise using the actor’s personality rights must be removed.
The Court further directed that BSI (Basic Subscriber Information) details be provided within three weeks. On the issue of AI-generated content and deepfakes, the Court observed that further consideration was required. Justice Arora stated,
“I am not clear on the AI issue yet and will consider it further. No orders for now.”
The matter has now been listed for further hearing in May 2026.
Case Title:
RANGANTHAN MADHAVAN V/s G FIMLZ STUDIOZ & ORS., CS(COMM)- 1392/2025
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