Delhi HC Grants Interim Protection To Kumar Sanu’s Personality Rights, Restrains Unauthorised Use of Voice and Image [Read Order]

New Delhi: The Delhi High Court has granted interim protection to renowned playback singer Kumar Sanu’s personality rights, restraining unauthorized commercial use of his name, image, and voice—including through Artificial Intelligence (AI) and other technological tools like machine learning, face morphing, and GIFs.

The court of Justice Manmeet Pritam Singh Arora was hearing applications seeking permanent and mandatory injunctions restraining infringement of copyright, misappropriation of personality/publicity rights, dilution, passing off, and other ancillary reliefs.

The plaintiff’s counsel, Ms. Sana Raees Khan, submitted that the defendants comprise a range of AI platforms, online intermediaries, and digital entities engaged in unauthorized use of Kumar Sanu’s voice, image, and likeness. Defendants 1–5 are AI platforms generating synthetic recordings imitating the plaintiff; Defendant 6 (YouTube/Google) and Defendant 7 (Meta Platforms) host and circulate such AI-generated or distorted content; Defendants 9–12 are websites commercially exploiting his name; Defendants 13–16 are e-commerce sellers marketing merchandise featuring his image; and Defendants 17–19 are GIF platforms enabling sharing of visuals using his likeness.

Counsel submitted that these infringements involve misuse of advanced technologies including AI—replicating or manipulating the plaintiff’s voice and image, morphing his face into videos, distorting expressions, and overlaying offensive audio—thereby exploiting his persona without consent.

Google’s counsel, Mr. Aditya Gupta, stated that the plaintiff provided a list of infringing URLs on 12 channels for takedown on October 13, 2025. He submitted that one URL had become unavailable, one appeared to be an actual recording of Indian Idol Season 14 and not AI-generated, and for the remaining URLs, Google would take them down as per court directions. He clarified that Tenordotcom (Defendant 17) and Google Play Store (Defendant 20) are owned by Google and would be represented by him.

Meta’s counsel, Mr. Varun Pathak, stated that the plaintiff raised grievances regarding four profiles on Facebook and Instagram. A list of 34 URLs provided on October 14, 2025, had now become unavailable, including URLs on the social media account impleaded as Defendant 8.

Flipkart’s counsel, Ms. Shilpa Gupta, and Amazon’s counsel, Mr. Vivek Ayyagari, stated they would abide by court directions. Mr. Om Ram accepted notice on behalf of MeitY (Defendant 21) and DoT (Defendant 22).

Justice Arora observed that the plaintiff has joined causes of action regarding unauthorized use of his personality rights by third parties to sell merchandise for commercial gains, impersonation on social media platforms, use of his attributes including voice through morphing and superimposing (including by AI), and creation of GIFs.

The court held:

“This Court is of the prima facie view that the Plaintiff is a notable singer/performer in India who has gained immense goodwill and reputation over the course of a very successful career and has acquired a celebrity status in India.”

Justice Arora referred to the earlier judgment in Karan Johar vs. Ashok Kumar (CS(COMM) 974/2025) dated September 17, 2025, observing that with the availability of advanced technology, it has become easy for entities to unauthorizedly use, copy, and imprint personality attributes of any celebrity for unearned commercial gains. Taking into consideration the commercial value of publicity rights, the court held that a celebrity is entitled to safeguard their interest against any misuse of personality attributes including name, image, voice, and likeness.

The court also relied on D.M. Entertainment vs. Baby Gift House, Anil Kapoor vs. Simply Life India (2023 SCC OnLine Del 6914), and Jaikishan Kakubhai Saraf @ Jackie Shroff vs. The Peppy Store (2024 SCC OnLine Del 3664), holding that there can be no dispute that celebrity status inherently grants proprietary rights over personality and associated attributes.

Justice Arora held:

“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 himself against morphed and distorted content which is demeaning.”

The court found that the plaintiff had established a prima facie case for grant of an ex-parte ad-interim injunction, with the balance of convenience in his favor. Justice Arora held that if injunction is not granted, irreparable loss and harm would be caused to the plaintiff’s reputation.

Accordingly, the court restrained Defendants 1, 2, 4, 5, 8, 12, 13, 14, 17, 19, and 23 from utilizing Kumar Sanu’s name, likeness, image, voice, personality, or any other aspects of his persona to create merchandise or in any manner misuse said attributes using technological tools such as AI, machine learning, face morphing, or GIFs—either for monetary gains or otherwise.

Defendants 1, 2, 4, and 5 (AI platforms) were directed to take down all infringing content on their websites. Google (Defendants 6, 17, 20) and Meta (Defendant 7) were directed to take down infringing content and provide BSI details including IP logs of account owners within three weeks.

The court directed that Google and Meta will act on the plaintiff’s future requests within 48 hours, and if they have any reservation, will communicate the same within 48 hours so that appropriate remedial steps can be taken.

Defendants 13 and 14 were restrained from selling merchandise infringing personality rights and directed to delist products within one week. Flipkart (Defendant 15) and Amazon (Defendant 16) were directed to take down infringing URLs.

MeitY and DoT (Defendants 21 and 22) were directed to require Internet Service Providers to suspend all infringing links, websites, and mobile applications.

Counsel appearing included Ms. Sana Raees Khan, Ms. Shikha Sachdeva, Ms. Kriti Rathi, and Ms. Annie Jacob for the plaintiff; Mr. Varun Pathak for Meta; Ms. Shilpa Gupta for Flipkart; Mr. Vivek Ayyagari for Amazon; Ms. Nidhi Raman with Mr. Om Ram for MeitY and DoT; and Mr. Aditya Gupta for Google entities.

Case Title: Kumar Sanu Bhattacharjee vs. Jammable Limited & Ors.

[Read Order]