Delhi High Court Shields Kriti Sanon From AI Deepfakes and Unauthorized Impersonation

Court Issues Sweeping Protections Against AI Misuse

The Delhi High Court on October 29, 2026, issued a comprehensive interim order protecting actor Kriti Sanon's personality rights against multiple forms of digital exploitation. Justice Purushaindra Kumar Kaurav restrained third parties from uploading, hosting, or generating content that infringes on her identity, including AI-generated deepfakes, morphed explicit content, and unauthorized use of her name, image, and voice.1

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The ruling addresses a commercial suit filed by Sanon against BBE Marketing Inc and others, alleging violations bound to cause irreparable harm to both her commercial interests and personal dignity.2

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The court's directive specifically targets several categories of infringement. BBE Marketing Inc was restrained from falsely representing an association with Sanon, particularly regarding offerings for her appearance bookings. Multiple defendants operating accounts on YouTube, Facebook, X, and Pinterest were ordered to stop circulating AI-generated and morphed images, sexually explicit material, chatbots presented as the actor, and synthetic voice models.1

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An online seller was also prohibited from marketing merchandise bearing attributes of Sanon's persona, including products using images from her personal life.2

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Legal Framework Distinguishes Privacy and Publicity Rights

Justice Purushaindra Kumar Kaurav provided critical clarity on the legal framework surrounding personality rights in India. The court observed that "personality rights" is not a single cause of action but encompasses distinct legal claims including publicity rights, privacy rights, passing off, defamation, and statutory intellectual property protections.2

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Notably, the order emphasized that no statute creates a unified personality right, requiring courts to identify the specific right allegedly infringed.

The judgment drew important distinctions between privacy and commercial exploitation. Privacy, dignity, and reputation are personal interests that cannot be assigned and end with the person, whereas publicity rights protect the commercial value of identity and can be licensed.2

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The court stated that publicity rights are "not the same as the right of privacy, though it has roots in it," referencing precedents from Titan Industries v. Ramkumar Jewellers and Digital Collectibles Pte. Ltd. v. Galactus Funware Technology Pvt. Ltd.

Balancing Legal Protections for Personality Rights With Free Speech

The interim order carefully balanced protection against infringement with constitutional free speech guarantees. Justice Kaurav clarified that the restraints do not apply to news, reviews, criticism, commentary, satire, parody, caricature, or fan expression that falls outside the prohibited categories.1

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This distinction acknowledges protections available under Article 19(1)(a) of the Indian Constitution for artistic and journalistic expression.

Gautam Bhatia, appointed as amicus curiae in related personality rights cases involving actors Janhvi Kapoor, Vivek Oberoi, and Aaradhya Bachchan, argued against treating personality rights as a monolithic legal concept. He urged courts to reject sweeping injunctions where claims remain undifferentiated, insisting plaintiffs must identify each legal interest, alleged harm, remedy sought, and countervailing rights including free speech.2

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Bhatia also cautioned against treating a person's image as property beyond statutory copyright and trademark protections.

Growing Trend of Celebrity Protection Against Digital Exploitation

Sanon joins a growing list of public figures seeking court intervention against digital misuse. Several prominent personalities including actors Aishwarya Rai Bachchan, Abhishek Bachchan, Salman Khan, Kangana Ranaut, Art of Living founder Sri Sri Ravi Shankar, journalist Sudhir Chaudhary, podcaster Raj Shamani, Andhra Pradesh Deputy Chief Minister Pawan Kalyan, and cricketer Abhishek Sharma have previously approached the Delhi High Court for similar relief and received interim protection.1

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The court also directed online intermediaries to remove identified URLs containing infringing content and ordered government authorities to block websites hosting pornographic deepfakes of Sanon. Google, identified as defendant No. 3, was the only intermediary to respond to Sanon's August communication, directing her to its reporting tool.2

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The court described intermediaries as "parties for compliance, not wrongdoers," requiring removal directions to specifically identify the material concerned. This interim arrangement remains in effect until the next hearing, when the court will examine the merits of personality rights claims after hearing contesting defendants.