Defendant by defendant and content by content: that is how a personality rights plaintiff must frame the case, the Delhi High Court has said while granting Kriti Sanon’s Personality Rights interim protection against AI-generated morphed images, deepfakes, impersonating accounts and chatbots.
New Delhi: The Delhi High Court has directed the takedown of web pages flagged by actor Kriti Sanon and restrained several defendants, including unidentified John Does, from circulating AI-generated sexually explicit or morphed content, impersonating her, or running chatbots and voice models presented as her, granting her interim protection against the unauthorised use of her name, image, likeness and voice [Kriti Sanon v. BBE Marketing Inc & Ors.].
Justice Purushaindra Kumar Kaurav passed the interim order in Sanon’s commercial suit on October 29, 2026, and listed the matter on December 10, 2026.
No single umbrella for personality rights
Before granting relief, the Court looked at what “personality rights” actually covers. It described the label as a bundle of distinct claims that can arise when a person’s identity is used without consent, including the right of publicity, privacy, passing off, defamation and rights under the trade mark and copyright statutes, each with its own elements, defences and remedies. It held:
“It follows that a plaintiff, as in the present case has, must indicate, defendant-wise and content-wise, which of these claims is made and on what material; and relief, particularly at the interim stage, must be correspondingly specific. All the claims in a suit of this kind cannot be put under one umbrella and met with one omnibus injunction.”
The Court also said the protection is not reserved for celebrities:
“The rights are available to every individual. Fame bears on whether an identity has commercial value and on the loss caused by its misuse; it is not a condition of the right. Equally, the mere use of a person’s identity is not, by itself, unlawful.”
What Sanon told the Court
Sanon told the Court that several accounts on YouTube, Facebook, X and Pinterest were falsely holding themselves out as her official representatives, and that some accounts were circulating AI-generated, morphed and sexually suggestive content using her likeness. She also flagged chatbots and voice models imitating her, image-generation services and merchandise carrying her name and image.
She had first complained to the intermediaries, which did not act, the Court noted, and it held that she could not be faulted for approaching the Court.
Intermediaries as parties for compliance
Referring to Section 79 of the Information Technology Act, 2000 and Shreya Singhal v. Union of India, the Court explained that intermediaries lose safe harbour only when they fail to act on actual knowledge, which means a court order identifying the material. It therefore declined to issue a general direction to remove “all other content” infringing personality rights, observing that the intermediaries “are, thus, parties for compliance, not wrongdoers” and that such a direction “would leave them to decide the very boundaries of the right that are in dispute.”
The duties under the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 also featured, including Rule 3(1)(b) on obscene, privacy-invading and impersonating content, and the 2026 amendment that brings “synthetically generated information” within these obligations.
The prima facie findings
Testing the flagged material defendant by defendant, the Court found prima facie that some defendants misrepresented an association with Sanon and impersonated her; that the AI-generated, morphed and sexually suggestive content of others engaged her privacy and dignity; that chatbots, voice models and image generation appropriated the commercial value of her identity and affronted her dignity; and that the pornographic deepfakes flagged in the suit “have no expressive value at all.”
Whether merchandise in which her image is itself the product falls within the right of publicity, the Court said, will be examined at the hearing.
The directions
Until the next date of hearing, the Court directed specified intermediaries to take down or disable access to the identified URLs within the time prescribed under Rule 3(1)(d) of the IT Rules, and the government defendants to issue blocking directions for the websites listed in the suit. It restrained the named defendants and the John Does from uploading, hosting, generating or making available further material of a similar nature, namely:
“(i) material impersonating the plaintiff or falsely representing an association with her; (ii) sexually explicit, obscene or morphed images, videos or audio of the plaintiff, including AI-generated ones; (iii) chatbots or voice models presented as the plaintiff; and (iv) merchandise of the kind placed on record.”
The Court made clear the limits of the order:
“Nothing in this order restrains news, review, criticism, commentary, satire, parody, caricature or fan expression which does not fall within the directions specified in para 32.”
It added that its observations are prima facie and only for the interim arrangement.
Why the order matters
Personality rights suits by film stars have become routine in the Delhi High Court, and many have ended in sweeping injunctions against “all” misuse of a name or face. This order pushes back on that pattern. It asks plaintiffs to say which right is infringed, by whom and through what material, and it keeps intermediaries in the role of complying with specific orders rather than policing an undefined right.
At the same time, the Court drew a firm line on AI-generated sexual content, deepfakes and chatbots built on a real person’s identity, while expressly protecting news, criticism, satire and fan expression. Its statement that the right belongs to every individual, not only the famous, may matter well beyond celebrity litigation as synthetic media spreads.
Case Title: Kriti Sanon v. BBE Marketing Inc & Ors. [CS(COMM) 1132/2026]
Bench: Justice Purushaindra Kumar Kaurav, Delhi High Court
Date of Order: October 29, 2026
Appearances: Mr. Pravin Anand with Mr. Dhruv Anand, Mr. Ameet Naik, Mr. Dhananjay Khanna and Ms. Bhavya Verma, Advocates, for the plaintiff; Ms. Mamta Rani Jha with Mr. Rohan Ahuja, Ms. Shruttima Ehersa and Ms. Manisha Singh, Advocates, for Defendant No. 3; Ms. Amee Rana with Ms. Sana Banyal and Mr. Intisar Aslam, Advocates, for Defendant No. 7