Bombay High Court Protects Personality Rights Of Kartik Aryan, Directs Take Down Of AI-Generated & Disparaging Content

The Bombay High Court, while protecting the 'personality rights' of Bollywood actor Kartik Aryan, observed that the Artificial Intelligence (AI) generated content with regard to the actor is, prima facie, obscene and disparages his reputation and lowers his brand value.

Single-judge Justice Sharmila Deshmukh, on April 15, passed an interim order protecting Aryan's personality rights and ordered various social media intermediaries to delete or pull down content which is unauthorised, objectionable and sexually explicit, as flagged by the actor in his plea.

Justice Deshmukh noted that Aryan is a popular and well-known film personality having multiple successful films, and well-known for brand endorsement and has awards to his credit and that his presence in movies and brand endorsements has leveraged his personality attributes over which he has 'exclusive right.'

The judge referred to the material placed on record by Senior Advocate Dr Birendra Saraf, who represented Aryan. The material basically included some fake websites claiming to be booking for the actor's performances, some merchandise being marketed using fake or AI images of Aryan, and also some websites, fake profiles on social media platforms like Facebook, X, YouTube etc. The material further highlighted AI-generated pornographic content showing Aryan, which was submitted in a sealed envelope.

Having perused the material on record, Justice Deshmukh held that the same indicated unauthorised exploitation of Aryan's personality attributes.

"The infringing website advertising itself as a medium for booking the performances by the Plaintiff implies a false association with the Plaintiff and carries strong possibility of duping the public. Prima facie, the material which has been annexed to the plaint would demonstrate the need for an immediate restraint order. Prima facie, at this stage, there cannot be any objection to the relief of injunction and deleting the infringing URLs. The facts in the plaint asserts about the Plaintiff being a notably public personality with inherent rights over his personality and associate attributes. The right of publicity protects an individual against unauthorised exploitation of their personality attributes including their name, image, likeness, voice and other distinctive attitudes," Justice Deshmukh observed.

"The material on record prima facie makes out a case of violation of the Plaintiff's personality/publicity rights and right to privacy. The unauthorised use of the Plaintiff's personality right for commercial purpose has the effect of diminishing the Plaintiff's brand value. This Court has perused the sexually explicit AI generated content tendered in a sealed envelope which is prima facie prejudicial to the Plaintiff's reputation. The obscene and disparaging content uploaded on public viewing platform needs urgent deletion/delisting," the judge said.

Insofar as the artificial intelligence chat- bot platform is concerned, the judge noted that such a platform permits the user to chat with the chat-bot which responds as the Plaintiff would. "Through such user, the voice, image and likeness of the Plaintiff's persona is sought to be commercially exploited without consent," the judge said.

With these observations, the bench ordered delisting or deleting the objectionable content available on the internet, along with the content created with the help of AI. The intermediaries are directed to pull down such content within 36 hours of it being flagged by Aryan.

The matter has been posted for further hearing on June 10.

Appearance:

Senior Advocate Dr. Birendra Saraf along with Advocates Ameet Naik, Madhu Gadodia, Aman Saraf, Amruta Thakur and Unnati Gambani instructed by Anand and Naik appeared for Kartik Aryan.

Advocates Nishad Nadkarni, Nirupan Lodha, Aasif Navodia, Khushboo Jhunjhunwala, Jaanvi Chopra and Rakshita Singh instructed by Khaitan and Co. represented Talkie & Redbubble.

Advocates Charu Shukla and Reeti Shetty represented Google LLC.

Advocates Harit Lakhani and Abhishek Mookherjee instructed by Shardul Amarchand Mangaldas and Co. represented Meta Platforms Inc.

Case Title: Kartik Aryan vs Vinsm Globe Private Limited [Interim Application (L) 9466 of 2026]

Citation: 2026 LiveLaw (Bom) 196

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