What becomes of a personality rights suit when some defendants settle and others never turn up? The Delhi High Court has decreed actor Amitabh Bachchan personality rights suit against a video-call app developer, a quiz book publisher, poster and T-shirt sellers, domain registrants and unknown John Doe infringers.
New Delhi: A commercial suit filed by actor Amitabh Bachchan to protect his name, image, voice and likeness, first heard in 2022 against a set of named defendants and unidentified online infringers, has ended in a decree of the Delhi High Court four years on [Amitabh Bachchan v. Rajat Nagi & Ors.].
In an oral judgment dated November 5, 2026, Justice Purushaindra Kumar Kaurav decreed the suit against four defendants on the basis of a written settlement and against the remaining non-appearing defendants and the John Does under Order VIII Rule 10 of the Code of Civil Procedure (CPC). The ex-parte ad-interim injunction granted on November 25, 2022 now stands merged with the decree.
Why the judgment matters
Personality rights suits in the Delhi High Court usually end at the interim stage, with ex-parte injunctions and takedown orders. This one has been carried to a final decree. It shows how the Court combines a partial compromise under Order XXIII Rule 3 with a judgment on default under Order VIII Rule 10 to close a case where some defendants settle and others simply stay away.
Extending the final decree to John Does matters for celebrities whose persona is misused by anonymous operators who cannot be traced in advance. A temporary shield becomes a permanent one, with room left for fresh proceedings if new misuse arises.
Who was sued
The suit sought a permanent injunction against misappropriation of the actor’s publicity rights, passing off, and damages. According to the judgment, the defendants included the developer of a mobile application titled “Amitabh Bachchan Video Call”, a person who circulated WhatsApp messages bearing the actor’s photograph to promote a purported “Kaun Banega Crorepati” lottery, a publisher that sold a general knowledge quiz book with his image on the cover, sellers of T-shirts and wall posters carrying his photographs, the registrants of the domain names amitabhbachchan.com and amitabhbachchan.in, and the registrars of those domains.
On October 9, 2026, the Court had noted that some parties were exploring settlement and had deferred the hearing to November 16, directing that the actor remain personally present if the settlement failed and he wished to press the suit.
Settlement with four defendants
A joint application under Order XXIII Rule 3 CPC informed the Court that the dispute stood settled with defendant nos. 1, 3, 5 and 8, who acknowledged the actor’s publicity rights and right to privacy. Defendant No. 1, Rajat Nagi, said he had taken steps to delete the video-call app; Manoj Publications said it had discontinued the quiz book; the poster seller said it had stopped selling the posters; and defendant No. 8 said he had deleted the domain amitabhbachchan.in in November 2022 and made no money from it.
Each of them undertook not to use the actor’s name, image, voice, likeness or any other aspect of his persona without express permission, binding their heirs and assigns. In return, the actor gave up his claims for damages and other reliefs against them.
Relying on Gurpreet Singh v. Chatur Bhuj Goel, the Court held that a compromise with some defendants can be given effect to against those defendants alone, and found the settlement lawful, in writing and duly signed.
“The settlement has been agreed upon without fear or coercion, and the parties appear to have entered into it on their own volition. Nothing has been pointed out which would render it void or voidable under the Indian Contract Act, 1872.”
Decree against defendants who never appeared
Defendant nos. 2, 4, 6 and 9 never appeared or filed written statements, and their right to do so was closed on September 25, 2023. Citing Asma Lateef v. Shabbir Ahmad, the Court cautioned that Order VIII Rule 10 is not to be applied mechanically, but found no disputed question of fact requiring trial.
Applying the test of validity and identifiability from Titan Industries Ltd. v. M/s Ramkumar Jewellers, the Court said:
“Both elements are satisfied. The impugned uses employ the plaintiff’s very name and photographs, for commercial gain and without his consent, and falsely suggest his endorsement. The plaint does not disclose any disputed question of fact requiring trial, and no purpose would be served in relegating the plaintiff to lead ex-parte evidence, which would merely repeat the plaint.”
The Court also noted that Rule 27 of the Delhi High Court Intellectual Property Rights Division Rules, 2022 permits summary judgment in such cases.
Decree extends to John Does
The 2022 injunction had operated against unknown infringers as well, and the plaint disclosed “a continuing pattern of anonymous misuse” through websites, apps, posters and messaging platforms. The Court therefore directed that the decree also operate against defendant No. 10, the John Does. The actor was given liberty to file fresh proceedings on a fresh cause of action, and the November 16 date was cancelled.
Case Title: Amitabh Bachchan v. Rajat Nagi & Ors. [CS(COMM) 819/2022, I.A. 30836/2026 and I.A. 30837/2026]
Bench: Justice Purushaindra Kumar Kaurav, Delhi High Court
Date of Judgment: November 5, 2026
Appearances: Senior Advocate Sandeep Sethi with advocates Pravin Anand, Ameet Naik, Madhu Gadodia, Dhruv Anand and others for the plaintiff; advocates S.C. Singhal and Parth Mahajan for defendant No. 1; Vinay Mohan Sharma for defendant No. 3; Tina Garg, M.K. Ghosh and Annirudh Gupta for defendant No. 5; Kushal Kumar and Tanya Manik for defendant No. 8
