The Madras High Court observed social media content may be ordered taken down if it amounts to commercial exploitation of an individual’s personality rights. The remark arose in a high-profile dispute involving chef T. Rangaraj and designer Joy Crizildaa.
CHENNAI: The Madras High Court has noted that social media content can be ordered to be removed if it constitutes commercial exploitation of a person’s personality rights.
This observation arose during a high profile case involving celebrity chef and entrepreneur T. Rangaraj and costume designer Joy Crizildaa.
Justice N. Senthilkumar was reviewing interim applications filed by Rangaraj in a commercial suit aiming to prevent Joy Crizildaa and unidentified parties from disseminating what he claimed to be defamatory material against him across social media, television channels, and digital platforms.
Also Read: Delhi High Court Protects Singer Kumar Sanu’s Personality Rights And Publicity Rights
Rangaraj claimed that Joy Crizildaa, who initially contacted him as a professional costume designer in December 2023, began to post photographs, videos, and interviews that misrepresented them as a married couple.
He asserted that these posts led to widespread sharing on various YouTube channels and television debates, allowing third parties to monetize this content unlawfully by exploiting his identity. He argued that over 150 YouTube channels and numerous social media accounts had reused this content, which constituted a clear infringement of his personality rights.
Rangaraj alleged that this content had inflicted irreparable damage on his reputation, family life, and business interests in both hospitality and entertainment.
In her defense, Joy Crizildaa countered that Rangaraj had falsely represented himself as judicially separated from his wife and that they were married on December 24, 2023, in a temple in Chennai. She claimed their relationship resulted in multiple pregnancies and abortions, ultimately leading to the birth of a child in October 2025.
To support her claims, she presented photographs from the temple ceremony, WhatsApp conversations, medical records, and a lease agreement identifying them as husband and wife. She argued that her posts were a legitimate expression of her rights and not defamatory.
In reviewing the arguments from both sides, the court observed that Rangaraj admitted in his pleadings to having an intimate relationship with Crizildaa. The court also highlighted that both parties made serious allegations, including claims of marriage, cohabitation, and paternity, which could not be definitively resolved at this preliminary stage.
Crucially, the court addressed the extent of relief in cases concerning potential misuse of personality rights on digital platforms.
Justice Senthilkumar remarked that court intervention is warranted where online content strays from personal assertion into commercial exploitation, particularly when a person’s identity is profited from by others via rebroadcasts, interviews, or sensationalized content.
The court made it clear that in such cases, takedown orders could be issued to prevent ongoing commercial gains from disputed material.
At the same time, the judge emphasized that prior restraint on speech, particularly in defamation disputes, must be approached with caution.
Citing established legal principles, the court indicated that interim injunctions preventing publication cannot be granted unless it is evident that the defense of justification would fail at trial.
The court stated that,
“Merely furnishing the links and photographs will not be sufficient for the court to prima facie come to the conclusion that there is a violation of personality rights …The plaintiff (Rangaraj) is only making an attempt to shut the voice of the individuals or the social media who are airing their views which are against him.”
Furthermore, the court noted that Rangaraj had not provided evidence showing he promptly objected to the posts by sending legal notices or filing police complaints at the relevant time.
It also acknowledged the criminal proceedings initiated against Rangaraj based on Crizildaa’s complaint and the recommendations made by the Tamil Nadu State Commission for Women, which went unchallenged.
The court concluded that Rangaraj had not established a case against Crizildaa, and since the balance of convenience and potential irreparable harm favored Crizildaa, it dismissed the interim requests.
The court ordered that,
“In view of the above discussions, both the applications are dismissed. No costs. Post the Suit in the usual course,”
Case Title: T.Rangaraj vs. Ms.Joy Crizildaa, John Doe/s
Read Attachment:
FOLLOW US FOR MORE LEGAL UPDATES ON YOUTUBE
