Delhi HC Protects Kriti Sanon’s Personality Rights Against AI Deepfakes and Impersonation

The Delhi High Court has granted actor Kriti Sanon interim protection against the unauthorised use of her name, image, likeness and voice, including through artificial intelligence-generated deepfakes, impersonation accounts and synthetic voice models. The court has directed online intermediaries to remove specifically identified objectionable content and restrained several defendants from creating or circulating similar material.

Justice Purushaindra Kumar Kaurav passed the order on October 29, 2026, in a commercial suit filed by Sanon against BBE Marketing Inc and others. The court’s directions cover sexually explicit or morphed images, videos and audio, AI chatbots presented as the actor, impersonating accounts and certain merchandise. However, the court also made clear that legitimate news reporting, criticism, commentary, satire, parody, caricature and fan expression are not prohibited. The case is scheduled for its next hearing on December 10, 2026.

Key Takeaways

• The Delhi High Court has granted interim personality-rights protection to actor Kriti Sanon.
• The order covers AI-generated sexually explicit deepfakes, morphed images, impersonation accounts and synthetic voice models.
• Online intermediaries have been directed to remove or disable access to specifically identified URLs.
• The court restrained named defendants and unidentified John Does from generating or circulating similar prohibited content.
• The court said personality rights are a collection of distinct legal claims, not one single cause of action.
• It emphasised that plaintiffs must identify the alleged infringement defendant by defendant and content by content.
• News, criticism, commentary, satire, parody, caricature and legitimate fan expression remain protected if they do not fall within the specified prohibited categories.
• The next hearing is scheduled for December 10, 2026.

Delhi High Court Grants Interim Protection to Kriti Sanon

Kriti Sanon approached the Delhi High Court seeking protection against the alleged misuse of her identity across online platforms and digital services.

Her complaint covered the unauthorised use of her name, photographs, likeness and voice by individuals and online accounts. The alleged misuse included fake social media profiles, AI-generated images, sexually suggestive content, synthetic voice models and chatbots presented as the actor.

The court examined the material submitted in the case and found that certain defendants had prima facie impersonated Sanon or falsely suggested an association with her.

It also observed that some AI-generated and morphed content raised concerns involving her privacy and dignity. Other material, including chatbots and voice models presented as the actor, raised questions about the unauthorised commercial exploitation of her identity.

Based on these preliminary findings, Justice Kaurav granted limited interim protection.

The order restrains the specified defendants, including unidentified John Does, from uploading, hosting, generating or making available further material of a similar prohibited nature.

The court also directed relevant intermediaries to take down or disable access to the identified URLs within the time prescribed under the Information Technology Rules, 2021.

The order is interim in nature. It does not represent a final determination of every legal claim raised in the lawsuit.

What Content Has the Court Restricted?

The court’s directions cover several categories of alleged misuse of Sanon’s identity.

These include material that impersonates the actor, falsely represents an association with her or uses AI tools to create sexually explicit and morphed images, videos or audio.

The order also addresses chatbots and voice models presented as Sanon, along with certain merchandise placed on record in the lawsuit.

The main categories covered by the interim directions include:

Category	Content covered by the order
Impersonation	Accounts or material falsely representing an association with Kriti Sanon
AI-generated deepfakes	Sexually explicit, obscene or morphed images, videos and audio
Synthetic voices	AI-generated audio or voice models presented as the actor
AI chatbots	Chatbots impersonating or presented as Sanon
Unauthorised merchandise	Merchandise of the kind specifically placed on record in the case
Online content	Identified URLs containing objectionable material

The court also directed the concerned government authorities to issue blocking directions for websites identified in the proceedings, particularly those hosting pornographic deepfake material.

The restrictions are tied to the categories and material identified in the case. They should not be interpreted as a prohibition on every online use of the actor’s name or image.

Court Warns Against Blanket Personality-Rights Injunctions

One of the most significant aspects of the ruling is the court’s examination of how personality-rights cases should be presented and decided.

The court observed that the expression “personality rights” does not describe one single legal cause of action. Instead, it can involve several distinct legal protections, each with its own requirements.

These may include:

• Right of publicity: Protects the commercial value associated with an individual’s identity.
• Right to privacy: Protects personal information, private life and individual autonomy.
• Passing off: Addresses misleading representations that may create a false impression of association or endorsement.
• Defamation: Concerns statements or representations that harm a person’s reputation.
• Trade mark rights: May apply where the legal requirements for protection under trade mark law are satisfied.
• Copyright and performers’ rights: May apply to protected creative works and performances where the statutory conditions are met.

Justice Kaurav emphasised that these claims cannot automatically be grouped together under a single broad request for protection.

The court said plaintiffs must explain which particular right has allegedly been infringed, identify the defendant responsible and specify the material involved.

This is particularly important at the interim stage, when courts may be asked to issue urgent restrictions before the defendants have fully presented their arguments.

A broad injunction covering every possible use of a person’s identity could create uncertainty about what is legally prohibited.

The court therefore stressed that relief must be specific to the alleged infringement and the evidence placed before it.

Personality Rights Are Not Limited to Celebrities

Another important observation in the ruling concerns who can claim personality-rights protection.

The court stated that such rights are available to every individual and are not restricted to actors, public figures or celebrities.

Fame may influence the commercial value associated with a person’s identity and the extent of financial loss caused by its misuse. However, the court said fame is not a condition for the existence of these rights.

This distinction separates the existence of a legal interest from the commercial value of that interest.

For example, a well-known actor may have a commercially valuable identity because brands and advertisers pay for endorsements. An ordinary individual may not have the same commercial value attached to their name or likeness, but that does not mean their privacy, dignity or identity can be freely exploited.

The court also clarified that simply using another person’s identity does not automatically amount to unlawful conduct.

The legality of the use depends on the circumstances, the rights involved, the purpose of the use and the applicable legal requirements.

This observation is relevant beyond celebrity lawsuits because AI tools now make it easier to reproduce faces, voices and other identifying characteristics of ordinary individuals.

Why the Court Distinguished Publicity Rights From Privacy Rights

The ruling also examines the difference between privacy and publicity.

Privacy, dignity and reputation are personal interests. They concern an individual’s personal life and cannot simply be treated as commercial assets.

The right of publicity, by contrast, protects the commercial value of a person’s identity. It can allow an individual to license the use of their name, image or likeness for advertising, endorsements and other commercial purposes.

The distinction matters because the same unauthorised use of an individual’s identity may raise different legal issues depending on how the material is used.

For example, a commercial advertisement falsely suggesting that an actor endorses a product may raise questions involving publicity rights and passing off.

An AI-generated sexually explicit image may instead raise serious concerns involving privacy, dignity and the unauthorised use of personal identity.

The court’s approach indicates that these issues should be examined separately rather than automatically treated as identical forms of infringement.

AI Deepfakes and Synthetic Voices Raise New Legal Challenges

The case comes amid growing concerns about the use of generative AI to create realistic images, videos and audio featuring real people.

Modern AI tools can generate images that resemble a person’s appearance, create synthetic voices and produce conversational systems that imitate an individual’s identity.

These capabilities have legitimate applications in areas such as entertainment, accessibility, creative production and digital services. However, they can also be misused to produce fabricated material that falsely depicts individuals or suggests that they have endorsed products, services or statements.

For public figures, the commercial implications can be significant because their identities are often associated with advertising contracts, endorsements and professional reputations.

The concerns become more serious when synthetic media is used to create sexually explicit or humiliating representations without consent.

In Sanon’s case, the court found prima facie that certain AI-generated and morphed material affected her privacy and dignity. It also examined the use of chatbots and synthetic voice models presented as the actor.

The court described the pornographic deepfakes placed before it as having no expressive value.

The ruling therefore provides interim protection against specific forms of AI-enabled misuse while leaving broader legal questions for consideration after the defendants are heard.

Online Platforms Must Comply With Specific Takedown Directions

The judgment also addresses the responsibilities of social media platforms, websites and other online intermediaries.

Sanon had alleged that her identity was being misused across several online services, including social media accounts and websites. The court considered the role of intermediaries under Section 79 of the Information Technology Act, 2000, which provides conditional protection from liability for third-party content.

The court referred to the legal principles established in Shreya Singhal v. Union of India while discussing when intermediaries are required to act on unlawful online material.

It explained that intermediaries are generally required to comply with valid court orders identifying the relevant content. They should not be left to independently decide the boundaries of a disputed personality right through a vague instruction to remove all allegedly infringing material.

The court described intermediaries as parties required to comply with its directions rather than automatically treating them as wrongdoers simply because third-party material appeared on their platforms.

This distinction is important because online platforms host enormous volumes of user-generated content.

A direction requiring them to remove every possible use of a person’s identity, without identifying the specific material or legal basis, could leave platforms responsible for making complex legal decisions without adequate guidance.

The court therefore directed the relevant intermediaries to take down or disable access to the identified URLs in accordance with the applicable Information Technology Rules.

Court Also Refers to Rules on Synthetically Generated Information

The court considered the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, including provisions dealing with unlawful content and impersonation.

It also referred to the 2026 amendments concerning synthetically generated information.

These rules are relevant because AI-generated content can create new challenges for online platforms. Synthetic images, videos and audio may appear realistic, making it difficult for users to distinguish fabricated material from genuine recordings.

The court’s order provides a specific legal direction for the intermediaries involved in the case.

It also reinforces the importance of identifying the particular URLs and content that are alleged to violate a person’s rights.

The ruling does not establish that every AI-generated representation of a real person is automatically unlawful. The nature of the material, the purpose of its use, the rights involved and the applicable legal requirements remain important considerations.

Court Protects News, Criticism and Satire From the Restrictions

While granting protection to Sanon, the court also made an explicit distinction between unlawful impersonation and legitimate expression.

It clarified that the interim order does not restrict news reporting, reviews, criticism, commentary, satire, parody, caricature or fan expression that does not fall within the prohibited categories.

This safeguard is important because public figures are frequently discussed, portrayed and referenced in news reports, films, reviews, commentary and online conversations.

Personality-rights protection should not automatically prevent legitimate public discussion or creative expression.

The court’s approach attempts to address both concerns: protecting individuals from unauthorised exploitation and preventing an overly broad injunction from restricting lawful speech.

The distinction also reflects the court’s wider position that the mere use of someone’s identity is not automatically unlawful.

Each claim must be evaluated based on its facts and legal basis.

What Happens Next in Kriti Sanon’s Case?

The interim order was passed on October 29, 2026, in the case titled Kriti Sanon v. BBE Marketing Inc & Ors., registered as CS(COMM) 1132/2026.

The court has scheduled the next hearing for December 10, 2026.

The defendants will have an opportunity to respond to the allegations and contest the claims raised by Sanon.

The court will then have to examine the issues in greater detail, including the different legal rights involved, the nature of the disputed content and the responsibilities of the parties.

The current directions are limited to interim protection. The court has expressly stated that its observations are prima facie and do not constitute final findings on the merits of the case.

The outcome could have wider relevance for future disputes involving AI-generated content, digital impersonation and the commercial use of an individual’s identity.

The Bigger Picture

The Kriti Sanon ruling highlights a growing legal challenge created by generative artificial intelligence: the ability to reproduce a person’s face, voice and identity at scale without their permission. As AI-generated images, synthetic voices and conversational systems become more accessible, courts are increasingly being asked to determine how existing protections for privacy, publicity and reputation apply to new forms of digital content.

The Delhi High Court’s approach is notable because it combines protection against specific forms of harmful impersonation with a warning against overly broad restrictions. By requiring claims to be identified defendant by defendant and content by content, the court has emphasised the need for precise legal relief. Its recognition that personality rights extend to every individual, while preserving legitimate criticism and satire, also gives the ruling significance beyond the entertainment industry.

Frequently Asked Questions

1. What did the Delhi High Court rule in Kriti Sanon’s case?

The Delhi High Court granted interim protection against the unauthorised use of Kriti Sanon’s name, image, likeness and voice. It directed the removal of identified objectionable URLs and restrained specified defendants from creating or circulating similar prohibited material.

2. Does the order cover AI-generated deepfakes?

Yes. The order covers sexually explicit, obscene or morphed images, videos and audio of the actor, including AI-generated content.

3. Are AI chatbots and synthetic voices also covered?

Yes. The court restrained the specified defendants from making available chatbots or voice models presented as Kriti Sanon without authorisation.

4. Does the ruling ban all use of Kriti Sanon’s photographs or name?

No. The order is limited to specified categories of prohibited material and identified content. The court clarified that legitimate news, reviews, criticism, commentary, satire, parody, caricature and fan expression are not restricted if they do not fall within the directions.

5. What are personality rights?

Personality rights refer to legal protections that may arise when an individual’s identity is used without consent. Depending on the circumstances, they can involve privacy, publicity, passing off, defamation and intellectual property rights.

6. Are personality rights available only to celebrities?

No. The Delhi High Court observed that these rights are available to every individual. Fame may affect the commercial value of a person’s identity, but it is not a requirement for the existence of the rights.

7. Why did the court reject a blanket injunction?

The court said personality rights involve several distinct legal claims. Plaintiffs must identify the specific right allegedly infringed, the defendant responsible and the content involved rather than seeking one broad order covering every possible use of their identity.

8. When will the case be heard again?

The matter is scheduled for its next hearing before the Delhi High Court on December 10, 2026.

Looking Ahead

The next stage of the case will involve responses from the defendants and further judicial examination of the claims raised by Sanon. The court will need to consider the specific content, the legal rights involved and the extent to which the interim restrictions should continue. Its final assessment could provide further clarity on how Indian courts approach AI-generated impersonation and the unauthorised commercial use of personal identity.

For the wider digital ecosystem, the ruling reinforces the importance of responsible AI-generated content and clear procedures for addressing harmful material online. It also sends a message that protection against deepfakes must be balanced with legitimate freedom of expression. As generative AI becomes more widely used, the distinction between unlawful impersonation and lawful creative or journalistic expression is likely to remain an important legal issue.