Safiya Malik

The High Court of Delhi Single Bench of Justice Manmeet Pritam Singh Arora, while hearing a suit by a well-known film actor against various online platforms and unknown users, directed social media intermediaries and government authorities to take down specified deepfake videos, morphed images and unauthorised merchandise exploiting the actor’s name, image and persona, to block listed pornographic domains, and to furnish basic subscriber information of unidentified infringers. The Court further clarified that individuals seeking urgent removal of objectionable online content should first use the complaint and grievance mechanisms of the concerned platforms before seeking an ex parte injunction, observing that intermediaries appearing before the Court typically do not oppose requests for deletion of objectionable, unsavoury or inappropriate material.

The plaintiff, Ajay Devgn a Bollywood film actor with a career of over four decades, has approached the Delhi High Court alleging unauthorised use of his name, image and likeness. He states that some defendants impersonate him by offering event bookings, others sell unauthorised posters and merchandise, and several social media accounts disseminate AI-generated deepfake videos and morphed photographs, including content linked to pornographic websites.

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He pleads that these acts infringe his personality and publicity rights, performers’ rights under the Copyright Act, registered trademarks under the Trade Marks Act and common law protections against passing off, misappropriation and unfair competition. He seeks permanent and interim injunctions and related reliefs, relying on tabulated details of allegedly infringing activities, lists of URLs and domain names, screenshots from online platforms and documents concerning his trademark registrations and endorsements. He also relies on the Information Technology Act, the Intermediary Guidelines and an October 2025 SOP issued by MeitY to contend that intermediaries must adopt safeguards and respond to takedown requests.

Counsel for some social media intermediaries state that they will comply with any directions but suggest that takedown orders be addressed first to uploaders, with platforms acting if they do not comply. Counsel for the Union government submits that the designated authorities may block domain names rather than individual URLs and seeks clarity on the blocking relief claimed.

The Court recorded that “The present suit has been filed seeking permanent injunction restraining trademark infringement, passing off, copyright infringement, violation of common law rights, misappropriation of personality/publicity rights, performers’ right along with other ancillary reliefs against the Defendants.”

The Court stated that “On the basis of the assertions made in the plaint and perusal of documents filed on record, this Court is of the prima facie view that the Plaintiff is a well-known face in India who has gained immense goodwill and reputation over a course of a successful career and has acquired a celebrity status in India.”

It further recorded that “Therefore, prima facie, the Plaintiff’s personality traits and/or parts thereof, including the Plaintiff’s name, likeness, voice, and image are protectable elements of the Plaintiff’s personality rights. The Plaintiff is entitled to seek injunction against the use of his personality rights by third parties for selling merchandise for their commercial gains, without his authorisation.”

On AI-generated and morphed content, the Court observed that “In addition, the Plaintiff is prima facie entitled to protect himself against morphed and distorted content created with the use of AI technology which portrays the Plaintiff in a repugnant manner, subjecting him to humiliation and ridicule. The Plaintiff is also prima facie entitled to protect himself against the circulation of morphed pornographic content and AI-generated images portraying him in obscene setting with other celebrities including female celebrities.”

It noted that “The balance of convenience lies in favour of the Plaintiff, and the continuing availability of the infringing content would cause irreparable injury to the Plaintiff.”

Regarding recourse under the IT Intermediary Rules, the Court stated that “However, before issuing the ex-parte injunction, this Court notes that the AI generated images of the Plaintiff with other female celebrities uploaded by Defendant Nos. 8, 9 10 and 11 as well as anonymous users which as per the Plaintiff are in unsavoury and inappropriate scenarios and in some cases ex-facie obscene could have been reported to the concerned social media platform for take down in accordance with The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021 [‘IT Intermediary Rules’], as it is an efficacious remedy provided by the statute to a complainant (such as the Plaintiff) which is not only cost effective but also time sensitive.”

The Court further recorded that “The intent of the statutory mechanism is to provide an effective remedial mechanism to the complainant as well as to reduce burden on the judicial system. Moreover, this Court observes that the social media intermediaries appearing in Court proceedings do not object to such complaints for taking down the unsavoury and inappropriate content. Therefore, it is clarified that if henceforth a complainant/plaintiff approaches the Court without availing the statutory mechanism provided under the IT Intermediary Rules, the said party may be held to be not entitled to an ex-parte ad-interim injunction, and the Court will direct the party to first avail its remedy under the aforesaid Rules. It is the obligation of the counsel to advise the litigant about this statutory remedy.”

The Court granted an interim injunction restraining the main contesting defendants, their associates and all persons acting for or through them from using, exploiting or misappropriating Ajay Devgn’s name, image, voice or likeness by any means, including AI-based tools, deepfakes or morphed content, on any online or virtual medium without his consent.

It directed specific defendants to take down infringing URLs, links, products and content listed in Annexure A from their platforms within 72 hours, with backup obligations imposed on search engines and other intermediaries to remove or de-index the material if the primary defendants do not comply. Certain government authorities were instructed to issue directions to internet service providers to block infringing domains and websites associated with unidentified “John Doe” parties, while domain registrars were asked to lock or suspend non-compliant domains.

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Several intermediaries were ordered to furnish basic subscriber information relating to the infringing URLs and domains within four weeks and to act on future requests for removal of mirror or identical content within 48 hours, or communicate any objections within the same timeframe. Relevant defendants were also directed to file compliance affidavits within four weeks, and procedural compliance under Order XXXIX Rule 3 CPC was directed within ten days.

Advocates Representing The Parties

For the Plaintiff: Mr. Pravin Anand, Mr. Ameet Naik, Ms. Madhu Gadodia, Mr. Dhruv Anand, Mr. Abhishek Kale, Ms. Udita Patro, Ms. Nimrat Singh, Mr. Dhananjay Khanna, Ms. Unnati Gambani, Mr. Pranav Nair

For the Defendants:Mr. Manas Raghuvanshi, Mr. Vivek Ayyagari and Ms. Misthi Dubey, Ms. Mamta Rani Jha, Mr. Rohan Ahuja, Ms. Shruttima Ehersha, Mr. Varun Pathak, Mr. Yash Karunakaran, Mr. Mritunjoy Roy, Ms. Nidhi Raman, CGSC with Mr. Om Ram and Mr. Mayank Sansanwal.

Case Title: Ajay alias Vishal Veeru Devgan v. The Artists Planet & Ors.
Case Number: CS(COMM) 1269/2025
Bench: Justice Manmeet Pritam Singh Arora