Every Success Or Milestone Can't Be Elevated To 'Personality Right', Expanding Doctrine Would Lead To Absurdity: Delhi High Court

The Delhi High Court has cautioned against an over-expansive interpretation of the doctrine of “personality rights”, observing that not every success or individual achievement can be elevated to the level of a legally enforceable personality right.Justice Tushar Rao Gedela made the observation while dealing with a commercial dispute between rival edtech platforms in the context of the CLAT 2026 topper controversy. The Court was examining claims involving alleged misuse of the CLAT Topper's identity by the institutions. While noting the content against her, it observed that she was appeared to have been drawn into the dispute despite clarifying her position.Thus the Court protected her from any disparaging content but at the same time clarified that the same is "not at all" based or predicated on her alleged personality right.The Court observed that though there is no precise definition of “personality rights”, however, it is prudent to avoid such enlargement and widening of the scope to the levels of incongruity and absurdity.“In case any and every success, or a milestone achieved is held to be sufficient to be raised to the level of a “personality right”, it would lead to absurdity and incongruity. If such interpretation is carried forward, then every aspirant, candidate, student, citizen of this country, who achieves or is declared as a top ranker in every stage of examination, would be entitled to protection of their “personality rights”.”In the same breath, the Court clarified that this is not to say that the individual achievers who may have achieved continuous top rank results over many years in various examinations, received awards in sporting events, musical maestros, artists of repute, business persons recognised globally or countrywide, political or religious leaders and such like persons in other spheres of life etc., may not have, what may constitute “personality rights”.“...yet it cannot be a sole or a single instance which would lend credence to a person to agitate violation of “personality rights”. The threshold cannot be brought down to individual events, though, that by itself may also not be a bar and may be assessed or ascertained on a case to case basis.”Reliance was placed on D.M. Entertainment Pvt. Ltd. vs. Baby Gift House and Ors. (2010) where the High Court held that an excessive emphasis on publicity rights can tend to restrain the exercise of democratic right to free speech.Eventually, the Court restrained the defendants from publishing any defamatory content against the plaintiff-company and barred the use of the topper's name, image or any AI-generated or morphed content associated with her.Notice was issued in the main suit and the matter will be taken up for further proceedings on August 24.Case title: Toprankers Edtech Solutions Private Limited & Ors. v. Lpt Edtech Private Limited And Ors.Appearance: Mr. J. Sai Deepak, Senior Advocate with Mr. Ankur Khandelwal, Mr. Chirag Sharma, Mr. Nikhil Saurabh and Mr. Sidhhi, Advocates for PlaintiffsCase no.: CS(COMM) 344/2026Click here to read order

Every Success Or Milestone Can't Be Elevated To 'Personality Right', Expanding Doctrine Would Lead To Absurdity: Delhi High Court

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