In a landmark ruling, the Delhi High Court has granted interim protection of personality rights to celebrated playback singer Kumar Sanu, restraining several artificial intelligence-based platforms, online intermediaries, and e-commerce entities from misusing his name, image, and voice for commercial purposes.
The order, passed by Justice Manmeet Pritam Singh Arora, marks a significant development in the growing intersection of AI, privacy, and celebrity rights, especially as deepfakes and unauthorized digital content continue to proliferate online.
Court Grants Interim Injunction in Favour of Kumar Sanu
In the case titled Kumar Sanu Bhattacharjee v. Jammable Limited & Ors., the Delhi High Court restrained all defendants from exploiting Kumar Sanu’s personality attributes — including his name, likeness, image, voice, and persona — for any commercial or unauthorized purpose until the next hearing on March 30, 2026.
Justice Arora observed that the singer’s personality elements are protectable under the law and cannot be used to create morphed, AI-generated, or misleading content that damages his goodwill and reputation.
“Prima facie, the Plaintiff’s personality traits and/or parts thereof, including the Plaintiff’s name Kumar Sanu, voice, image, photograph or likeness and other attributes are protectable elements of the Plaintiff’s personality rights. The Plaintiff is entitled to protect itself against morphed and distorted content which is demeaning,” the Court stated.
The Case: AI Platforms and Fake Content Misusing Sanu’s Persona
Kumar Sanu, one of India’s most loved playback singers, filed a ₹2 crore lawsuit before the Delhi High Court against several artificial intelligence-driven platforms, online intermediaries, digital entities, and unknown persons for misusing his persona.
The suit alleged that these entities created fake, AI-generated, and morphed content imitating his voice and image, impersonated him on social media platforms, and even sold unauthorized merchandise using his photographs and name.
Further, an app hosted on the Google Play Store was found exploiting Sanu’s personality by falsely associating itself with him. The singer stated that such acts violated his privacy, goodwill, and personality rights, and caused him emotional distress as well as reputational harm.
AI, Deepfakes, and Personality Rights
Kumar Sanu emphasized the growing misuse of artificial intelligence in creating deepfakes and AI-generated voice clones, arguing that such technologies were being weaponized to exploit his fame.
He pointed to distorted sound recordings imitating his voice and graphic content (GIFs) carrying his image and caricatures, which circulated widely across Instagram, Facebook, and YouTube, often subjecting him to unsavoury humour and ridicule.
According to his counsel, these digital reproductions not only misappropriated his identity but also violated his right to publicity — a recognized facet of the right to privacy under Indian law.
Arguments on Behalf of the Plaintiff
Appearing for Kumar Sanu, Advocate Sana Raees Khan argued that the defendants’ actions constituted a violation of personality rights, unauthorized commercial exploitation, and passing off, besides infringing provisions of the Copyright Act, 1957.
The plaintiff contended that his public persona and reputation have distinct commercial value, cultivated over decades in the entertainment industry.
“The names ‘Kumar Sanu’, ‘Sanu Da’, and the title ‘The Melody King of Bollywood’ have two layers of protection — firstly under the Plaintiff’s Personality/Publicity Rights (where misappropriation does not require confusion) and secondly under Trade Mark Law and/or Passing Off (which requires likelihood of confusion as to source or association),” the suit stated.
The counsel further emphasized that AI platforms and e-commerce sites have a duty of due diligence under the Information Technology Act, 2000, to prevent and remove infringing content upon notice.
Court’s Observations and Directions
The Delhi High Court upheld Sanu’s plea and observed that celebrity personality traits — name, image, voice, and likeness — are protected attributes of one’s persona and cannot be used without consent.
Justice Arora cited previous rulings protecting the personality rights of Bollywood actors Anil Kapoor, Karan Johar, and Jackie Shroff, emphasizing judicial consistency in addressing digital impersonation and AI misuse.
Key Directions Issued:
- Amazon and Flipkart were directed to take down listings selling merchandise that infringed Sanu’s personality rights.
- Two e-commerce sellers were specifically restrained from continuing such sales.
- Google and Meta (Facebook) were instructed to remove infringing content listed in Sanu’s petition and take down any new violations flagged by him in the future.
- These platforms must also share Basic Subscriber Information (BSI) of anonymous users who created or uploaded such content within three weeks.
- The Ministry of Electronics and Information Technology (MeitY) and the Department of Telecommunications (DoT) were ordered to suspend infringing URLs, websites, and mobile applications identified by the singer.
These proactive measures reflect the judiciary’s growing recognition of digital privacy and personality protection in the age of artificial intelligence.
Why This Ruling Matters
The Delhi High Court’s order is being hailed as a milestone in celebrity personality rights jurisprudence. It extends the protection of reputation and identity to digital and AI-generated contexts, setting a precedent that may benefit artists, public figures, and creators whose likenesses are being exploited without consent.
1. Strengthening Personality Rights
The judgment reinforces that personality traits — including a person’s name, image, likeness, and voice — are intellectual and moral assets deserving legal protection, especially against digital replication.
2. Tackling AI Deepfakes
The case adds judicial weight to the argument that AI-generated impersonations, or “deepfakes,” can violate both privacy and commercial rights of individuals.
3. Intermediary Accountability
By directing e-commerce platforms and social media intermediaries to take immediate action and disclose user data, the Court strengthens accountability under the IT Act and Intermediary Guidelines, 2021.
4. Encouraging Safe AI Innovation
While the order protects individuals, it also sends a signal to the tech industry to develop AI responsibly, ensuring that creative technologies do not infringe upon human dignity or identity.
Counsel Appearances
- For Kumar Sanu: Advocates Sana Raees Khan, Shikha Sachdeva, Kriti Rathi, and Annie Jacob
- For Meta (Facebook): Advocates Varun Pathak, Yash Karunakaran, and Debditya Saha
- For Amazon: Advocates Vivek Ayyagari and Abhinav Bhalla
- For Flipkart: Advocates Shilpa Gupta and Surabhi Pande
- For Google: Advocate Aditya Gupta
- For MeitY and DoT: Central Government Standing Counsel Nidhi Raman with Advocate Om Ram
Conclusion
The Delhi High Court’s interim injunction in favour of Kumar Sanu is not just a victory for one artist but a crucial step in defining the contours of digital identity protection in India. As artificial intelligence blurs the lines between real and artificial, the judiciary has reaffirmed the importance of human consent and dignity in the digital era.
By directing major tech platforms and government agencies to act decisively, the Court has sent a strong message — AI cannot be a tool for exploitation. Personality rights, like copyright and privacy, are integral to protecting creative professionals in today’s virtual world.
This ruling, alongside earlier decisions involving Anil Kapoor, Karan Johar, and Jackie Shroff, contributes to a growing body of Indian jurisprudence that recognizes the right to control one’s public image, ensuring that fame, identity, and artistic legacy remain in the hands of their rightful owners.
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