Madras High Court Passes John Doe Order Protecting Actor Kamal Haasan's Personality Rights, With Relief Against Illegal Exploitation, But No Bar On Satire
Safiya Malik
The Madras High Court on Monday (January 12) granted interim protection to the personality rights of actor and Rajya Sabha MP Kamal Haasan, restraining unknown persons and entities from misusing his name, image, or likeness for unlawful purposes, including commercial merchandising.
At the same time, the court clarified that legitimate creative expression would not be curbed, noting that satire and caricature remain permissible. After hearing the matter, Justice Senthilkumar Ramamoorthy issued the following order:
“Senior counsel (for plaintiff) invited my attention to several photographs of morphed images. Submits that these images are causing incalculable damage to his reputation and image as celebrity Counsel also refers to the use of plaintiff's image, name and the like on merchandise without the plaintiff's consent or endorsement. Upon examining the above, a strong prima facie case is made out. Therefore, the respondents are restrained from creating false images of the plaintiff and depicting the same through any media until next hearing. Respondent also restrained from selling merchandise bearing plaintiff's name or image without consent or endorsement. This order will not however stand in the way of caricature, satire or other forms of permissible creative expression."
The High Court further noted that since a “John Doe” party has been included as the second respondent—typically used when specific perpetrators are not fully identifiable—the actor was directed to issue public notice of the order in both English and Tamil newspapers.
Senior Advocate Satish Parasaran, appearing for Haasan on behalf of advocate Vijayan Subramanian, submitted that the petition sought a John Doe order because several unidentified entities were allegedly profiting by using Haasan’s persona without consent. During the hearing, the court orally observed: “In these matters, we also need to be mindful that there's freedom of expression. Things like caricature, satire are all expression”.
Parasaran responded that while freedom of expression must be respected, it cannot extend to commercial exploitation of an individual’s persona without permission. Haasan approached the court seeking to restrain third parties from commercially exploiting his personality and moral rights. The petition also referenced the High Court’s earlier intervention protecting the personality rights of musician Ilaiyaraaja.
In his submissions, Haasan highlighted a career spanning more than six decades across multiple Indian languages, along with numerous awards and honours. He argued that his public reputation and endorsements have significant commercial value, and that elements such as his name, signature, voice, image, and other identifying attributes should not be used, imitated, or misappropriated without authorisation.
He further claimed that certain online platforms were selling merchandise—such as T-shirts—bearing his name and photograph in a way that could suggest his approval. The petition also alleged that altered or AI-generated content falsely depicting him was being circulated online, sometimes in vulgar or explicit forms, with the creators allegedly monetising such material.
Haasan therefore sought a John Doe injunction to bar unidentified third parties from commercially exploiting his distinctive attributes without his prior consent or authorisation
Case Title: Kamal Haasan v Neeyevidai
Case No: OA 17 /2026 and C.S (Comm Div) 8/2026
Bench: Justice Senthilkumar Ramamoorthy
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