Anil Kapoor v. Simply Life India & Ors.

Anil Kapoor is a Hindi film actor whose career spans more than four decades. He sued in the Delhi High Court in 2023 over the unauthorised commercial use of his persona online. The defendants included sellers of merchandise bearing his face, websites and social media accounts, operators of domain names built on his name, and unknown persons, sued as 'John Doe' defendants, who were creating and circulating manipulated content.¹

The plaint listed many kinds of misuse. These included generative-AI images showing the actor in different personas, morphed and pornographic deepfake videos combining his face with those of well-known actresses, and GIFs and memes distributed for commercial gain. It also cited ringtones and ringback tones using his voice and film dialogues, and merchandise such as t-shirts, magnets, cups, stickers and masks printed with his image or with 'jhakaas', the Marathi slang word he popularised. The plaint further described fake autographed photographs, squatted domains (anilkapoor.in, anilkapoor.net and anilkapoor.com), and false listings offering him as a motivational speaker for a fee.¹⁵

The suit followed earlier Delhi High Court personality-rights orders, such as the November 2022 John Doe order for Amitabh Bachchan. It went further by focusing on generative AI and deepfakes, which Bar & Bench reported the actor said were being used to damage his goodwill and reputation.⁵

Justice Prathiba M. Singh granted an ex parte ad interim injunction in CS(COMM) 652/2023 on 20 September 2023. Paragraph 48 restrained Defendants 1 to 16 and anyone acting for them from using Anil Kapoor's 'name, likeness, image, voice, personality or any other aspects of his persona' to create merchandise, ringtones or ringback tones. It also barred them from otherwise misusing those attributes 'using technological tools such as Artificial Intelligence, Machine Learning, deep fakes, face morphing, GIFs', whether for monetary gain or otherwise, to create videos, photographs and similar content for commercial purposes.¹

The court also made a series of directions to make the injunction effective online:¹

• Domain registrars were directed to lock and suspend the three anilkapoor domains immediately and to disclose the registrants' details within a week. The domains were to be transferred to the plaintiff on payment of the usual charges.
• Pornographic deepfake videos at 44 listed URLs were to be taken down.
• The Department of Telecommunications and the Ministry of Electronics and Information Technology were added as Defendants 22 and 23 and asked to issue blocking orders for the pornographic links and any future uploads. Government counsel was asked to communicate the order to them.

The court found that the plaintiff had established a prima facie case, that the balance of convenience lay in his favour, and that without an injunction he and his family would suffer irreparable harm, 'not only financially but also with his right to live with dignity'.¹

Personality rights as privacy and dignity. The court rooted personality rights in the right to privacy, relying on the Supreme Court's decision in R. Rajagopal v. State of Tamil Nadu (1994), and in the dignity protected by Article 21 of the Constitution. It noted that fame can bring its own disadvantages. A well-known person's name, voice and image are vulnerable precisely because they carry value, and their misuse affects not only income but also privacy and dignity.¹

Publicity and endorsement value. The court treated the commercial value of a celebrity persona as deserving protection. It observed that the celebrity's right of endorsement is 'a major source of livelihood' that cannot be destroyed by allowing the unlicensed sale of merchandise bearing the celebrity's face or attributes. It drew on US right-of-publicity decisions, such as Midler v. Ford Motor Co. on voice imitation and White v. Samsung on evoking a persona, and on the Delhi High Court's own discussion of personality rights in Digital Collectibles v. Galactus Funware (2023).¹

Passing off and dilution. The unauthorised use suggested endorsement or association that did not exist and could deceive the public. Use in degrading or pornographic content tarnished the actor's reputation. The court found that the actor's distinctive delivery of 'jhakaas' was 'exclusively synonymous' with his persona, even though the order did not treat the word as a registered trademark.¹

Technology and AI. The court recognised that the technology itself had changed the risk. It said that tools now freely available make it possible for any unauthorised user 'to use, produce or imitate any celebrity's persona', including by using AI. That reasoning justified a broad injunction against unknown persons and directions to platforms and the government.¹

Free speech limits. The court accepted that genuine news, information, satire, parody and criticism remain protected. When such use crosses a line, however, and becomes tarnishing, deceptive or commercially exploitative, it becomes illegal. The injunction was therefore framed around commercial misuse and violation of the plaintiff's rights, rather than any reference to him at all.¹

The suit went through the court's usual procedure for commercial cases. On 30 April 2024 Justice Sanjeev Narula decreed the suit against Defendants 2, 4 to 10, 12 and 13. He confirmed the interim injunction and directed Defendant 11 to ask IndiaMart to remove the actor's picture.² On 13 November 2024 Justice Amit Bansal decreed the suit against Defendant 11, granting the reliefs in paragraphs 104(i) to (v) of the plaint. He recorded that the anilkapoor.com domain had been locked and gave the plaintiff time to settle with Defendant 3.³

Against the remaining defendants the suit continued. By July 2025 it was proceeding only against Defendants 15, 16 and 24. Defendants 15 and 24 had lost the right to file written statements and were proceeding ex parte.⁴ On 30 October 2025 Justice Manmeet Pritam Singh Arora also proceeded ex parte against Defendant 16, who had been served by publication but had not appeared.⁶

The order became the model for India's later wave of personality-rights injunctions against AI misuse. Its approach of restraining misuse through named technologies such as AI, deepfakes and GIFs was followed in later orders, beginning with the May 2024 order for Jackie Shroff.⁸ It is still cited as authority. In October 2026, for example, the court relied on it when issuing a permanent injunction against AI-generated deepfake videos falsely showing cardiac surgeon Dr. Devi Prasad Shetty endorsing medical products.⁹

The order has also drawn criticism. Writing on SpicyIP, Prof. Sunanda Bharti questioned whether image rights should override established doctrines. She pointed to links targeting resellers of decades-old vintage postcards of the actor on eBay, which she argued should be protected by copyright's first-sale (exhaustion) principle, and to the doctrine of laches.⁷ Later commentary compared the order with the more nuanced Jackie Shroff order of May 2024, which refused to restrain a YouTuber's affectionate 'tribute' video. That commentary argued that broad John Doe injunctions risk sweeping in fan creators, meme makers and resellers whose own livelihood and expression deserve weight.⁸

The order is an interim, ex parte order made without a contest on the merits. Like most personality-rights orders that followed, it was not tested in a full trial. Indian law on personality rights has therefore developed largely through interim injunctions rather than final judgments.

As of 14 October 2026, the interim injunction of 20 September 2023 remains in force. The suit has been decreed against several defendants and is pending against the rest.²³⁶ On 24 August 2026 Justice A.J. Bhambhani could not take up the matter because the Supreme Court had directed him to hear another batch of cases day to day. He renotified the suit for 16 November 2026.¹⁰