Bombay High Court Grants Interim Injunction to Suniel V Shetty in Landmark Personality Rights Case
Court Prohibits Unauthorized Use of Actor's Name, Image, and Persona in AI-Generated Content and Advertisements
In a landmark judgment delivered on October 10, 2025, the Bombay High Court has granted an ex-parte interim injunction in favor of renowned Indian actor and public figure, Suniel V Shetty, in a case concerning the unauthorized use of his personality rights. The case, titled "Suniel V Shetty v. John Doe S Ashok Kumar," was presided over by Justice Arif S. Doctor, who ruled in favor of the plaintiff, protecting his personality rights, right to privacy, and right to live with dignity under Article 21 of the Indian Constitution.
The court's decision comes after Shetty filed a suit seeking protection against the unauthorized use of his name, image, voice, likeness, and other identifiable attributes, including AI-generated content and deepfakes, by various parties on social media platforms and the internet. The court found that such unauthorized commercial exploitation constituted an infringement of Shetty's personality rights, a violation of his right to privacy, and his right to live with dignity.
In his submission, Dr. Birendra Saraf, the Advocate General representing Suniel V Shetty, emphasized the unique association of the actor's personality with his name, image, and other attributes, arguing that any unauthorized use constitutes an infringement of his fundamental rights. The defendant parties were accused of engaging in various infringing activities, including the circulation of AI-generated images, unauthorized advertisements, and false endorsements, among other violations of Shetty's personality rights.
The court directed intermediaries like Meta Platforms and X Corp to remove infringing content upon notification and to share details of the infringing parties to facilitate legal action. The order also highlighted the duty under the IT Rules, 2021, to prevent the misuse of platforms.
Justice Arif S. Doctor stated in his judgment that the materials presented revealed a clear infringement of the plaintiff's rights, causing harm to his personality rights. The court found that the plaintiff had made a strong case for immediate relief, citing potential irreparable harm to his reputation and goodwill.
The court's decision is seen as a significant step in protecting personality rights in the digital age, particularly against the misuse of AI-generated content and deepfakes. The order serves as a precedent for future cases involving unauthorized exploitation of personality rights and emphasizes the responsibilities of intermediaries like Meta Platforms and X Corp. to take down infringing content upon notification.
The judgment has been lauded as a landmark ruling that reinforces the protection of personality rights under the Copyright Act, 1957, and Article 21 of the Constitution of India, which guarantees the right to privacy and the right to live with dignity.
Bottom Line:
Unauthorized use of plaintiff's name, image, likeness, and other identifiable attributes, including AI-generated deepfakes, constitutes infringement of personality rights, violation of the right to privacy, and the right to live with dignity under Article 21 of the Constitution of India.
Statutory provision(s): Article 21 of the Constitution of India, Copyright Act, 1957, Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
Suniel V Shetty v. John Doe S Ashok Kumar, (Bombay) : Law Finder Doc id # 2792907
