Delhi High Court Grants John Doe Dynamic Injunction Protecting Actor Vivek Oberoi’s Personality Rights, Restrains Deepfake And AI Persona Misuse
Safiya Malik
The High Court of Delhi Single Bench of Justice Tushar Rao Gedela has granted a John Doe interim order protecting the personality rights of actor and entrepreneur Vivek Oberoi, issuing an ex-parte ad-interim dynamic injunction against multiple identified defendants and unknown entities. The Court restrained them from misappropriating or exploiting the plaintiff’s name, image, voice, likeness and other distinctive attributes, including through artificial intelligence, deepfakes, face morphing and other digital technologies, for commercial or other gain. It also directed certain online sellers, intermediaries and platforms to remove specified infringing links within 72 hours of the order being uploaded and to furnish relevant account and login details to the plaintiff within three weeks.
Oberoi instituted a commercial suit alleging misappropriation of various facets of his personality, including his name, image, likeness, persona and voice, asserting that these attributes are exclusively associated with him. The suit was accompanied by applications seeking discovery, exemption from filing certain documents, exemption from pre-institution mediation under Section 12A of the Commercial Courts Act, 2015, exemption under Section 80(2) CPC from serving prior notice to government authorities, and an ex parte ad interim injunction under Order XXXIX Rules 1 and 2 CPC.
The plaintiff contended that several defendants, including intermediaries and unidentified parties, were misusing his personality rights by creating and disseminating infringing content, including AI-generated and morphed videos, posters, merchandise, and social media posts. Annexure-A to the order, spanning pages 22 to 29, lists 122 allegedly infringing links across websites, social media platforms, and video-sharing services. The plaintiff asserted statutory and common law copyright, personality/publicity rights, and the right to privacy under Article 21 of the Constitution of India.
The Court observed that “having heard the learned counsel for the plaintiff and perusing the contents of the plaint and after having examined the various documents on record containing the images, links and other purported infringing material and actions, this Court is of the considered opinion that an ex-parte ad-interim injunction is in order.”
It recorded that “the material placed on record as also the averments regarding the personality and other attributes of the plaintiff, clearly demonstrate that the plaintiff is an accomplished and established actor, apart from being an astute business person and a humanitarian.” The Court further stated that “the copyright of the plaintiff over his own personality, which include, amongst others, his image, likeness, voice, name, signature, which are distinctive and exclusively associated with him, cannot, prima facie, be doubted at this stage.”
The Court recorded that “plaintiff’s long standing career and stellar success in films… clearly demonstrate his goodwill, reputation and acceptability not only in the entertainment world but in the general public as well.” It stated that “prima facie, all the attributes noted above including his voice etc., are exclusively recognized by the general public and those in the entertainment industry, to the plaintiff alone.”
On the question of interim relief, the Court observed that “the plaintiff has a prima facie strong case and having regard to his well-known, popular and well-accepted personality, the balance of convenience is tilted in favour of the plaintiff.” It further recorded that “in case, ex-parte ad-interim injunction and other directions, as sought, are not passed, the irreparable loss and injury which may occasion may not be compensated in monetary terms.” The Court added that “the dent and damage to the image and personality of the plaintiff, prima facie, appears to be real and present.”
The Court ordered that “Defendant nos. 1 to 18, including John Doe(s), their associates, servants, agents, affiliates, holding companies, assignees, substitutes, representatives, group entities, their subscribers, employees and/or persons claiming through them or under them and all other persons are restrained from violating the plaintiff's personality/publicity rights and moral rights by utilizing and/or in any manner directly and/or indirectly, using or exploiting or misappropriating the plaintiff's (a) name ‘Vivek Oberoi’; (b) voice; (c) image and likeness and (d) other aspects of his persona that are identifiable with him for any commercial and/or personal gain and/or otherwise by exploiting them in any manner whatsoever, through the use of any technology including but not limited to Artificial Intelligence, Generative Artificial Intelligence, Machine Learning, Deepfakes, Face Morphing, and on any mediums and formats.”
“Defendants 1 to 18, including John Doe(s), their associates, servants, agents, affiliates, holding companies, assignees, substitutes, representatives, group entities, their subscribers, employees and/or persons claiming through them or under them are restrained from creating, sharing, disseminating, any product (including but not limited to clothes, tshirts, post cards, postcards, images, posters, books); content (including audio-visual content, images, videos etc.) through the use of any technology including but not limited to Artificial Intelligence, Generative Artificial Intelligence, Machine Learning, Deepfakes, Face Morphing, and on any mediums and formats, including but not limited to the physical medium, the virtual medium such as websites, Metaverse, social media etc. that results in dilution of the Plaintiff's public persona by either by blurring or tarnishment.”
“Defendant Nos. 1, 4, 9, 10, 19, 20, 21, and 22 are directed to take down all links/websites enlisted in Annexure-A attached to this order within 72 hours from the uploading of this Order, which infringes the plaintiff's personality/publicity rights and they shall provide BSI details and IP login details of the links/websites/account/videos/apps/posts of the defendant nos.1 to 18 and/or third parties to the plaintiff, within three weeks.”
In relation to the interlocutory application, the Court ordered, “Issue Notice. Let reply to this application be filed by the defendants within 4 weeks from service. Rejoinder thereto, if any, be filed within a period of two weeks thereafter. Compliance of Order XXXIX Rule 3 of CPC shall be carried out within ten (10) days from date.”
“Let the Plaint be registered as a Suit. Issue Summons. Let the Summons be served to the Defendant(s) through all permissible modes upon filing of the Process Fee. The Summons shall state that the Written Statement(s) shall be filed by the Defendant(s) within 30 days from the date of the receipt of Summons. Along with the Written Statement(s), the Defendant(s) shall also file an Affidavit of Admission / Denial of the documents of the Plaintiff, without which the Written Statement(s) shall not be taken on record.”
“The Plaintiff [is] to file Replication, if any, within 30 days from the receipt of the Written Statement(s). Along with the Replication filed by the Plaintiff, an Affidavit of Admission / Denial of the documents of Defendant(s) be filed by the Plaintiff, without which the Replication shall not be taken on record.”
“In case any Party is placing reliance on a document, which is not in their power and possession, its details and source shall be mentioned in the list of reliance, which shall also be filed with the pleadings. If any of the Parties wish to seek inspection of any documents, the same shall be sought and given within the prescribed timelines.”
“List before the learned Joint Registrar on 27.04.2026 for completion of service and pleadings. List before this Court on 05.08.2026.”
Advocates Representing the Parties:
For the Petitioners: Ms. Sana Raees Khan, Mr. Pranay Chitale, Mr. Udayvir Rana, Mr. Aditya Dutta and Mr. Dhawesh Pahuja, Advocates
Case Title: Vivek Anand Oberoi v. Collector Bazar & Ors.
Case Number: CS(COMM) 105/2026
Bench: Justice Tushar Rao Gedela
