NEW DELHI, Oct 16: Bollywood actor Kriti Sanon has approached the Delhi High Court seeking protection of her personality rights, bringing renewed attention to the legal challenges celebrities face over the unauthorised use of their identities in the digital age.
During a hearing on Friday, Justice Purushaindra Kumar Kaurav asked Sanon’s counsel, advocate Pravin Anand, to submit a detailed compilation of relevant judicial decisions and research material explaining the scope of personality rights and the legal principles governing such claims.
The court also raised questions about whether the High Court’s Intellectual Property Division (IPD) has the jurisdiction to hear disputes of this nature. It sought a broader examination of the legal framework before considering the matter further.
The next hearing has been scheduled for October 29.
Sanon’s petition comes amid growing concerns over the use of celebrity photographs, videos, voices and other identifiable characteristics without authorisation. The spread of artificial intelligence tools and digital impersonation has made it increasingly easy to reproduce a public figure’s appearance or voice in content that may be misleading or commercially exploitative.
Court seeks clarity on the scope of personality rights
During the proceedings, the court asked Sanon’s legal team to explain which aspects of an individual’s identity should receive protection and how existing legal precedents address such claims.
Anand submitted that personality rights could cover a person’s name, face, voice, photographs, images and videos. He also highlighted the issue of using someone’s identity for commercial purposes without their consent or authorisation.
The judge sought relevant research papers, judgments and legal analysis to examine these questions in greater detail. The court indicated that it would consider a comprehensive order after reviewing the material placed before it.
The request for further research is significant because personality rights disputes involve several overlapping legal questions. These include an individual’s interest in controlling the commercial use of their identity, the protection of privacy, the role of intellectual property law and the limits of unauthorised exploitation.
The court’s questions also concern the appropriate judicial forum for resolving such disputes. Determining jurisdiction is important because it establishes which division or court can hear a case and what procedures apply.
No final ruling on the broader legal issues had been delivered at the hearing reported on October 16.
What personality rights mean for celebrities
Personality rights generally refer to protections associated with a person’s identity, particularly where identifiable characteristics are used without permission in ways that may infringe privacy or exploit commercial value.
For actors and other public figures, a recognisable face, voice, name or likeness can carry substantial professional and commercial significance. Such attributes may be associated with film promotions, endorsements, advertisements and other paid engagements.
Unauthorised use can create confusion about whether a celebrity has endorsed a product, participated in a campaign or approved a particular statement. In other situations, fabricated content may damage a person’s reputation or mislead audiences about what they have said or done.
The legal questions can become more complicated when a person’s identity is reproduced through digital editing or artificial intelligence. A fabricated video may imitate a celebrity’s appearance and speech, while a synthetic voice may make it appear that the individual has delivered a statement they never made.
Personality rights claims can seek to address these concerns, although the exact protection available depends on the circumstances and the applicable law.
The issue is not limited to celebrities. Public figures, sports personalities, political leaders and other individuals whose identities carry commercial or reputational value may also face unauthorised use of their names, images or voices.
Artificial intelligence adds a new dimension
The rapid development of AI-generated content has intensified the debate over identity protection. Tools that once required specialised technical skills can now produce realistic images, audio and videos with relatively little effort.
This technology has legitimate applications in entertainment, visual effects, dubbing, satire and creative production. However, it can also be used to create misleading endorsements, fabricated interviews, impersonation videos and content that falsely attributes statements to real people.
For actors, the potential risks extend beyond the unauthorised reproduction of photographs. Digital tools can generate a likeness that appears to show a performer speaking or acting in circumstances in which they never participated.
Such content may affect reputation, commercial arrangements and public trust. It can also make it harder for audiences to distinguish authentic material from manipulated media.
The legal challenge is to establish appropriate safeguards without imposing unnecessarily broad restrictions on lawful expression, reporting, commentary or artistic work.
The court’s request for a detailed examination of personality rights could help clarify how existing legal principles apply to these emerging forms of digital misuse.
Balancing identity protection with freedom of expression
Protecting a person’s identity does not necessarily mean that every use of a celebrity’s name or photograph requires permission.
News organisations may refer to public figures while reporting on their professional activities. Critics may discuss a performance, commentators may analyse public statements, and filmmakers may use cultural references in creative works.
These activities raise different considerations from using a celebrity’s likeness to imply an endorsement or sell a product without consent.
A legal framework must therefore distinguish between legitimate expression and conduct that may unlawfully exploit an individual’s identity. The context, purpose and manner of use can be important when assessing a dispute.
An overly broad restriction could interfere with reporting, commentary, parody or artistic expression. Conversely, inadequate protection could leave individuals vulnerable to deceptive impersonation and unauthorised commercial exploitation.
The court’s request for judicial precedents and research indicates the importance of examining these competing interests rather than treating every instance of identity use in the same way.
A clearer understanding of the boundaries could help courts assess future cases consistently and provide greater certainty to both content creators and public figures.
A growing number of celebrity petitions
Sanon’s case comes amid an increase in personality rights litigation involving actors, sports personalities and other prominent individuals.
Courts have considered claims involving the unauthorised use of celebrity names, photographs, voices and likenesses in a range of circumstances. These disputes reflect growing concern about how digital platforms can reproduce and distribute identity-related material at scale.
For performers, an established public image can be closely linked to years of professional work. Unauthorised commercial use may raise questions about consent, endorsement and control over the value associated with their identity.
For businesses and digital creators, the disputes underline the importance of assessing permissions before using a public figure’s likeness in advertising or promotional content.
The growing number of cases also creates a need for consistent judicial reasoning. When similar disputes arise in different courts or divisions, uncertainty about applicable standards and jurisdiction can complicate proceedings.
The Delhi High Court’s request for a consolidated examination of earlier judgments is therefore relevant beyond Sanon’s individual petition. The material may assist the court in evaluating the legal principles that should guide such cases.
Implications for the entertainment industry
The issue has implications across film production, advertising, music, social media and streaming services.
Actors increasingly work across several platforms, and their images and voices can be distributed far beyond the original context in which they appeared. Promotional campaigns, fan-created content and AI-generated media can all circulate widely online.
Production companies and advertisers may need to pay closer attention to permissions, licensing arrangements and the terms governing the use of performers’ identities. Digital platforms also face questions about how to respond when users report allegedly unauthorised or deceptive content.
At the same time, the entertainment industry uses digital technology for legitimate creative purposes, including visual effects, dubbing and other forms of image or voice manipulation. Any legal approach must account for these applications while addressing potential misuse.
A more developed understanding of personality rights could help define the responsibilities of the parties involved and clarify the circumstances in which legal remedies may be available.
However, the outcome of Sanon’s petition will depend on the arguments, evidence and legal standards considered by the court. The request for further research should not be interpreted as a final determination of the merits of her claims.
What happens next in the case
The Delhi High Court has asked Sanon’s counsel to provide the requested legal material for further consideration. The next hearing is scheduled for October 29, when the court is expected to continue examining the issues raised during the proceedings.
The case places a prominent Bollywood actor’s request for identity protection within a wider debate about privacy, commercial exploitation and technological change.
As AI-generated media becomes more accessible, courts are increasingly confronted with questions about how existing legal protections apply to new forms of impersonation and reproduction.
The proceedings could contribute to the developing discussion on the scope of personality rights in India. Any broader legal conclusions, however, will depend on the court’s subsequent examination of the relevant judgments and arguments.
For the entertainment industry, the case serves as a reminder that a public figure’s identity can carry both personal and commercial value, and that its use may raise legal questions when consent, context and purpose are disputed.