Akshay Hari Om Bhatia vs John Doe S

Digitally signed by KAWRE KAWRE KIRAN 1 27 / 907-IA(L)-33184-2025 (OS).DOC KIRAN KALYAN KALYAN Date: 2025.10.16 19:01:01 +0530

IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION IN ITS COMMERCIAL DIVISION

INTERIM APPLICATION (L) NO. 33184 OF 2025 IN COMMERCIAL IP SUIT (L) NO. 32986 OF 2025

Akshay Hari Om Bhatia ... Applicant/Plaintiff

In the matter between

Akshay Hari Om Bhatia ... Applicant/Plaintiff Versus John Doe and Ors. ...Defendants/Respondents _______ Dr. Birendra Saraf, Senior Advocate a/w Mr. Janay Jain, Monisha Mane Bhangale, Bijal Vora & Chandragupta Patil i/b Parinam Law Associates for the Plaintiff. _______

CORAM : ARIF S. DOCTOR, J.

DATE : 15th OCTOBER 2025 P.C.

1. The Plaintiff has, by way of the present Suit, sought, inter alia, the

protection of his personality rights, his right to privacy, and his right to live with

dignity as granted under Article 21 of the Constitution of India, and also the

protection of his moral rights under the Copyright Act, 1957. The Plaintiff uses

the screen name "Akshay Kumar" right from the beginning of his career

spanning more than 35 years and has, over the years, been identified by that

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screen name, "Akshay Kumar". The Plaintiff asserts that personality rights, his

right to privacy, and his right to live with dignity, as well as his moral rights are

being infringed and violated through unauthorized use, commercial

exploitation, and misrepresentation on social media and e-commerce platforms

and across the internet by various entities, some of whom are impleaded as

Defendants.

2. The Plaintiff has, in the plaint, demonstrated his reputation as a renowned

film actor, producer, and public figure with a distinguished career in the Indian

film industry spanning over three decades. The Plaintiff has referred to the films

(more than 150 in number) in which he has acted in paragraph 23 of the plaint,

further detailed in Exhibit A at page 155 of the plaint. The Plaintiff's

performances in successful and acclaimed films, including " Hera Pheri",

"Airlift" ,"Khiladi", "Rustom", "Bhool Bhulaiyaa", and "Khakee", have garnered him

wide recognition as one of the foremost stars of his generation.

3. The Plaintiff has provided an illustrative list of the numerous awards and

honors he has received in paragraph 30 of the plaint. Notably, he was conferred

the Padma Shri in 2009 by the Government of India for his contribution to

cinema. Thereafter, he received the National Film Award for Best Actor for his

performances in "Rustom" and "Airlift" (2016). He has also been awarded two

Filmfare Awards, namely for Best Villain ( Ajnabee) in 2002 and Best Comedian

(Garam Masala) in 2006. Further, the Plaintiff was also conferred an Honorary

Doctorate of Law by the University of Windsor in 2008 and was the recipient of

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the Outstanding Achievement in Cinema at The Asian Awards in 2011, amongst

numerous other such accolades.

4. Further, the Plaintiff enjoys a substantial presence on social media

platforms. As detailed in paragraph 31 of the plaint, the Plaintiff has over 66.6

million followers on Defendant No. 2's platform Instagram, over 49 million

followers on Defendant No. 2's platform Facebook, and over 46 million

followers on Defendant No. 3's platform X (formerly Twitter). This extensive

digital following serves as tangible evidence of the Plaintiff's widespread

popularity, substantial public recognition, and the considerable goodwill he

commands in the public domain. It also reinforces the distinctiveness and

exclusive public association of the Plaintiff's indicia, including his name, image,

and persona, in the minds of the public.

5. Learned Senior Counsel points out that, as set out in paragraph 33 of the

plaint, the Plaintiff has endorsement arrangements with reputed brands, which

have associated themselves with the Plaintiff owing to his popularity, goodwill,

and credibility amongst the public. Dr. Saraf submits that the Plaintiff has, over

the years, built a distinct personal brand, such that the public associates his

screen name and persona with qualities of trust, credibility, and excellence. The

goodwill and recognition generated have created a strong nexus between the

Plaintiff's reputation and the brands, products, and commercial activities with

which he is associated.

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6. Dr. Saraf submits that the Plaintiff's personality, including his name,

screen name, signature, image, likeness, voice and tone, distinctive performance,

appearance, and mannerisms, have become uniquely identifiable with him in

the minds of the public. It is contended that the Plaintiff possesses an inherent

and enforceable right to control, protect, and commercially exploit his

personality, and that any unauthorized use or misappropriation thereof

constitutes not only a violation of his personality/publicity rights but also his

fundamental rights, as enshrined under the Constitution of India.

7. Dr. Saraf then drew the Court's attention to the specific instances that

necessitated the filing of the present Suit, which are detailed in paragraphs 46 to

55 of the plaint and in Exhibits "F", "G", and "H" annexed thereto. It is submitted

that the infringing activities are set out in the plaint in the following categories

of misuse and unlawful exploitation:

(i) The creation and dissemination of AI-generated deepfake videos and

morphed images,

(ii) Unauthorized voice cloning and impersonation,

(iii) Sale of merchandise bearing the Plaintiff's likeness, and

(iv) Other unlawful uses of the Plaintiff's persona, which collectively

demonstrate the systematic and continuing nature of the violations

complained of.

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8. Prior to adverting to the infringing content set out in the plaint, Dr. Saraf

drew my attention to a recent instance of such infringement, discovered

subsequent to the filing of the present Suit. In the said post

[https://www.instagram.com/reel/DPlgNE-D7Wa/?igsh=cWkzamcwZnl0cjNq],

the Plaintiff was depicted making communally provocative statements. It is

submitted that the said post was entirely an AI-generated deepfake video that

falsely attributed views and expressions to the Plaintiff. Dr. Saraf emphasized

that although the said post has since been taken down, the gravity of such

fabrications, particularly given how alarmingly realistic the deepfakes appear,

poses a serious risk not only to the Plaintiff's reputation but also to the safety and

well-being of his family members, as they involve the unauthorized use of the

Plaintiff's likeness and voice to convey inflammatory statements.

9. Dr. Saraf then proceeded to point out details of the various infringing

activities that necessitated the filing of the present Suit, as more particularly set

out in paragraphs 46 to 55 and in Exhibits "F", "G", and "H" of the plaint, and

which are essentially summarized as follows:

a) Unauthorized creation and dissemination of AI deepfakes/morphed

photos/videos:

(i) As pleaded in paragraphs 46.3 to 46.7 of the plaint, Defendant No. 1

(John Doe), operating on Defendant No. 4's platform, YouTube,

published/uploaded a purported trailer video titled " Maharshi

Valmiki - Teaser Trailer | Akshay Kumar as VALMIKI | Paresh

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Rawal | Pankaj Tripathi | 2025 ". This AI-generated video depicts

the Plaintiff in the role of Maharishi Valmiki by superimposing his

likeness, along with those of other actors, onto dramatic scenes

without his knowledge, involvement, or consent. It is submitted that

the said video went viral in or around September 2025, gaining

widespread circulation across multiple media outlets. The

deceptively realistic nature of the video misled the public into

believing it was genuine and had originated from the Plaintiff,

resulting in severe public criticism and reputational harm to the

Plaintiff.

(ii) Dr. Saraf, thereafter, submitted that the controversy surrounding the

said video even compelled the Plaintiff to issue a public clarification

on 23rd September 2025, wherein he categorically distanced himself

from the video and condemned the misuse of AI.

(iii) Despite such clarification, and though the video was eventually

taken down, Dr. Saraf submitted that the damage to the Plaintiff's

reputation was severe and enduring. The publication of this

deceptive video triggered significant outrage within the Valmiki

community, which found the unauthorized and misleading

portrayal of their revered saint to be deeply offensive. The same also

culminated in public protests in Jalandhar, thereby wrongfully

implicating the Plaintiff in communal disharmony.

(iv) Dr. Saraf further drew my attention to two additional videos

referenced in Paragraphs 46.1 and 46.8 of the Plaint, accessible at:

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(i) https://www.youtube.com/watch?v=h_9CS-5slXo, and (ii)

http://www.youtube.com/watch?v=HUWEWz37Mgw. These videos

are fake, edited, or AI-generated depictions portraying the Plaintiff

in fabricated movie trailers. In one such trailer, the Plaintiff is falsely

shown to be depicting the role of Yogi Adityanath, the Chief Minister

of Uttar Pradesh, with the said trailer having garnered over

20,00,000 views. In this light, Dr. Saraf submits that such

unauthorized use not only infringes upon the Plaintiff's right of

publicity but also damages his professional reputation, undermines

the goodwill built over his career, and harms his genuine upcoming

film projects.

(v) Dr. Saraf then highlighted the circulation of AI-generated

images/deepfakes by Defendant No. 1 on Defendant No. 2's platform,

Facebook, which depict the Plaintiff in an obscene manner. The

details of the infringing links, which are set out in paragraph 47.2 of

the plaint, are as follows:

Sr. Link

i.

https://www.facebook.com/share/1TV1k9odt1/?mibextid=wwXIfr

ii. https://www.facebook.com/share/p/1A6AU79N8e/?

mibextid=wwXIfr

iii. https://www.facebook.com/share/p/1BaLBU3bCk/?

mibextid=wwXIfr

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iv. https://www.facebook.com/share/p/1CjyPgWHxh/?

mibextid=wwXIfr

v. https://www.facebook.com/share/p/1BGdxXSkQH/?

mibextid=wwXIfr

vi. https://www.facebook.com/share/p/1JX1CXWhNN/?

mibextid=wwXIfr

vii. https://www.facebook.com/share/p/1JtpExpY7Y/?

mibextid=wwXIfr

(vi) Dr. Saraf thereafter pointed out certain AI-generated images

depicting the Plaintiff in various manipulated and fabricated

scenarios, designed to ridicule, demean, and harm his reputation,

dignity, and public standing. These posts, created using AI

technology, portray the Plaintiff in imaginary and absurd contexts,

including, inter alia, a post titled "When Bollywood celebrities forget

to eat protein", posts wherein the Plaintiff's likeness has been

superimposed onto images of a young schoolboy and a girl with a

toy, and such other distorted caricatured forms. Such depictions are

wholly unauthorized, derogatory and constitute a misuse of the

Plaintiff's persona for commercial engagement and digital traction.

The infringing links are set out in Paragraph 48 of the plaint as

follows:

Sr. Ref. in Links Ex. F

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https://www.instagram.com/p/DN- i. Sr. 1 CRgADfI3/

https://www.instagram.com/p/ ii. Sr. 2 DOsWXvpjUBn/

https://www.instagram.com/p/ iii. Sr. 3 DNpQ7c7M1FU/

https://www.instagram.com/p/ iv. Sr. 4 DNcbvUEOACv/

https://www.instagram.com/p/ v. Sr. 5 DNALkIcsXhp/

https://www.instagram.com/p/ vi. Sr. 6 DMmgnqlMi9F/

https://www.instagram.com/p/ vii. Sr. 7 DL4C4edMbLZ/

https://www.instagram.com/p/DLy8yZJM- viii. Sr. 8 fp/

https://www.instagram.com/p/ ix. Sr. 9 DLjk2YWsoW2/

https://www.instagram.com/p/ x. Sr. 10 DLaBMTVM8iv/

https://www.instagram.com/p/ xi. Sr. 11 DLCNuNpMaWl/

https://www.instagram.com/p/ xii. Sr. 12 DKqyxfes2xy/

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https://www.instagram.com/p/DJV- xiii. Sr. 13 pdkOZ7m/

(vii) Dr. Saraf further referred to a deepfake/morphed video mentioned

in paragraph 48.3 of the plaint, wherein the Plaintiff is falsely

depicted as promoting a betting and gambling application. The said

video is accessible at the following link:

https://x.com/Jessely35br/status/1752681354083569876?

ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm

%5E1752681354083569876%7Ctwgr

%5E6495708cbc3c46bd43a58abfd8b152461da02394%7Ctwcon

%5Es1_&ref_url=https%3A%2F%2Fnewschecker.in%2Ffact-check

%2Fdeepfake-ad-of-akshay-kumar-promoting-mobile-game-app-

goes-viral. With respect to the said video, Dr. Saraf submits that

what is particularly alarming is the deceptively realistic nature of

the video, wherein the lip synchronization is remarkably accurate

and indistinguishable from genuine footage.

b) Unauthorized offering of services (presumably via AI) impersonating or

cloning the Plaintiff's voice and infringing upon his persona (paragraph

50 of the plaint):

(i) Dr. Saraf submitted that Defendant No. 11 operates a platform that

advertises and purports to enable the use of an "AI Akshay Kumar

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v2 Voice" through its website, accessible at

https://www.jammable.com/akshay-kumar-v2-Iw5eq. In a

nutshell, this platform enables its users to generate new content

using the Plaintiff's voice. The illustrative image, as produced in

the plaint, is reproduced hereinbelow:

(ii) Further, Learned Senior Counsel stated that Defendant No. 12 has

created an AI chatbot by unauthorizedly exploiting the Plaintiff's

personality rights, using his screen name and image in a manner

likely to mislead the public into believing that the Plaintiff is

associated with or has endorsed the said website at

https://beta.opedia.ai/u/akshay-kumar/. The illustrative image

produced in the Plaint is reproduced hereinbelow:

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c) Unauthorized sale of merchandise/goods using images or AI-generated

images of the Plaintiff:

(i) Dr. Saraf submitted that Defendant Nos. 1, 8, and 9 are

unauthorisedly engaging in the sale of merchandise bearing

aspects of Plaintiff's persona, screen name, and image, and the

same is not only violating the Plaintiff's personality rights but also

undermining his commercial brand value. The illustrative details

of the infringing links, set out in paragraphs 51.1 to 51.2 of the

plaint, are set out below:

Ref. in Sr. Links Ex.

https://www.iceposter.com/gty?search=Akshay i. Sr. 1 %20Kumar&prods=1

ii. https://kashcollectiveco.com/products/akshay- Sr. 2

kumar-vintage-t-shirt?

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_pos=1&_sid=758af534e&_ss=r

(ii) Dr. Saraf further highlighted that even on the websites of

Defendant Nos. 5 to 7 (e-commerce platforms), rampant numbers

of merchandise infringing upon the Plaintiff's personality rights

are being listed and sold. He submits that these platforms are

actively listing and enabling the sale of unauthorized products

bearing the Plaintiff's screen name, image, and likeness, including

posters, t-shirts, mugs, and bobbleheads. Such unauthorized

commercial exploitation not only violates the Plaintiff's exclusive

right of publicity but also constitutes unjust enrichment at the

expense of the Plaintiff's goodwill and reputation. The illustrative

details of the infringing links, as set out in paragraphs 51.3 to 51.8

of the plaint, are set out below:

Sr. Platform Links (Hyperlinked) Ref. in Ex.

i. Redbubble Link 1 Sr. 4

ii. Redbubble Link 2 Sr. 5 Def. No. 5 iii. Redbubble Link 3 Sr. 6

iv. Redbubble Link 4 Sr. 7

v. Def. No. 6 Etsy Link 1 Sr. 8

vi. Etsy link 2 Sr. 9

vii. Etsy Link 3 Sr. 10

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viii. Etsy Link 4 Sr. 11

ix. Etsy Link 4 Sr. 12

x. Etsy Link 5 Sr. 13

xi. Etsy Link 6 Sr. 14

xii. Etsy Link 6 Sr. 15

xiii. Flipkart Link 1 Sr. 16

xiv. Def. No. 7 Flipkart Link 2 Sr. 17

xv. Flipkart Link 3 Sr. 18

d) Unauthorized/unlawful use/infringement of Plaintiff's persona:

(i) Dr. Saraf pointed out that Defendant No. 16 is selling a digital

sticker pack featuring the Plaintiff, accessible at

https://stickers.cloud/en/pack/akshay-kumar#google_vignette, as

referred to in paragraph 52.2 of the plaint. He further submitted

that Defendant No. 17 enables users to share short, looping

animated clips (GIFs) featuring the Plaintiff's image and likeness on

its platform, accessible at https://giphy.com/search/Akshay-Kumar,

as referred to in paragraph 52.3 of the plaint. In this regard, he

submits that the Plaintiff has never authorised the sale/offering of

such stickers or GIFs bearing his screen name or image, and that

the said Defendants are unauthorisedly exploiting the Plaintiff's

persona for their own commercial gain.

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(ii) Dr. Saraf further brought the Court's attention to acts of Defendant

No. 1 (John Doe/Ashok Kumar(s)), who have published posts on

Instagram, and presumably on other social media platforms, that

unauthorizedly infringe upon the Plaintiff's persona. A perusal of

these posts would indicate that advertisements for betting

apps/websites have been superimposed on images or videos

featuring the Plaintiff to falsely create the impression that the

Plaintiff endorses or is associated with such platforms. The details

of such infringing posts, referred to in paragraphs 52.6 and 52.7

of the plaint, are set out below:

Sr. Link

https://www.instagram.com/reel/ i. DPemaTSD4Ah/?igsh=amZneHJpYjB6dXoy

https://www.instagram.com/reel/ ii. DPeWnr1D8C4/?igsh=aW00dWlhNjdhaDkz

https://www.instagram.com/reel/

iii. DPd9WJzDz6e/?

igsh=MWd3anl2OW9mNnQ1aA==

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(iii) Dr. Saraf highlights that the Plaintiff has also come across

instances of unidentified users creating profiles to impersonate the

Plaintiff. The details of two such profiles, on Defendant No. 2's

Instagram and Facebook, referred to in paragraph 53 of the plaint,

are set out below:

Sr. Link

i. https://www.instagram.com/jr_khiladi_sandip/?hl=en

https://www.facebook.com/p/Akshay-kumar-action- ii.

king-of-bollywood-100059485752909/

10. Dr. Saraf further submitted that, in addition to the identifiable instances

of infringement, numerous other entities and individuals continue to operate

clandestinely, concealing their true identities. These unidentified persons engage

in similar infringing activities, including the unauthorized creation, publication,

and circulation of AI-generated, morphed, and deepfake content featuring the

Plaintiff, as well as the sale and promotion of products and services unlawfully

exploiting his persona. Due to the absence of verifiable information, the Plaintiff

is presently unable to ascertain the identities or contact details of such

infringers. Accordingly, while the Defendants whose particulars are known have

been specifically impleaded by name, all such unknown or anonymous persons

and entities have been collectively impleaded as "John Doe" (i.e., Defendant No.

1).

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11. Dr. Saraf further submitted that, as the details and identities of Defendant

Nos. 10 and 11 are presently not ascertainable, the Plaintiff has, for effective

adjudication, also arrayed the Domain Name Registrars (DNRs) of the websites

operated by the said Defendants as necessary parties to the present proceedings.

The inclusion of the concerned DNRs is to facilitate the disclosure of all available

information pertaining to the ownership and operation of the impugned

websites.

12. It is submitted that the aforesaid Defendants (Defendant Nos. 1, 8 - 13

and 16 - 17) are engaged in the systematic misappropriation and unauthorized

exploitation of the Plaintiff's identity for their own commercial and personal

benefit. This ongoing infringement not only unlawfully diverts the economic

value inherent in the Plaintiff's status but also poses a significant threat to the

Plaintiff's professional career and public standing. By exploiting the Plaintiff's

indicia, including his screen name, likeness, and reputation, these Defendants

achieve significant and quantifiable advantages on social media and other

online platforms, such as increased followers, engagement, and likes.

Furthermore, the use of various aspects of the Plaintiff's personality, such as the

creation of AI images/deepfakes/videos and GIFs, as well as the creation of false

and obscene images of the Plaintiff, is not only an infringement of his

personality rights but also a violation of his rights under Article 21 of the Indian

Constitution.

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13. With regard to the unauthorised appropriation and sale of merchandise

bearing the Plaintiff's personality attributes, including his image and likeness,

Dr. Saraf submits that such activities are likely to deceive the public into falsely

believing that the Plaintiff is associated with or has endorsed the concerned

commercial ventures. He submits that members of the public, relying upon the

Plaintiff's goodwill, may consequently transact with such entities to their

detriment. This concern is further amplified by specific instances (illustrated

above), including the deliberate misuse of the Plaintiff's likeness in promoting

betting and gambling applications, which creates a false and damaging

impression of the Plaintiff's endorsement of such illicit activities.

14. Dr. Saraf further submits that the incident where the Plaintiff was falsely

depicted as "Maharishi Valmiki" in a purported film trailer (referred to in

paragraphs 46.3-46.7 of the plaint) exemplifies the extent of misrepresentation

and misuse enabled by modern AI and deepfake technologies. Such

unauthorized and deceptive portrayals, it is urged, not only violate the Plaintiff's

personality and moral rights, but also possess the potential to mislead and harm

the public at large.

15. Dr. Saraf then relied upon a number of cases to submit that

unauthorisedly using a person's name, voice, dialogues, or images would be

impermissible, and in such cases the courts cannot turn a blind eye. In this

regard, he relied upon the following decisions: (i) Asha Bhosle v. Mayk Inc, 2025

SCC OnLine Bom 3485 (paragraph nos. 15 to 18); (ii) Arijit Singh v. Codible

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Ventures LLP and Ors., 2024 SCC OnLine Bom 2445 (paragraph nos. 16, 17,

and 18); (iii) Anil Kapoor v. Simply Life India and Ors., 2023 SCC OnLine Del

6914 (paragraph nos. 38, 39, 41 and 43); Jaikishan Kakubhai Saraf alias Jackie

Shroff v. Peppy Store and Ors ., 2024 SCC OnLine Del 3664 (paragraph nos. 12);

Aishwarya Rai Bachchan v. Aishwaryaworld.Com and Ors. , 2025 SCC OnLine

Del 5943 (paragraph nos. 33.25, 34 to 39); Karan Johar v. Ashok Kumar/John

Doe, 2025 SCC OnLine Del 6108 (paragraph nos. 34, 35, 36 and 37) and Suniel

Shetty v. John Doe/Ashok Kumar , Interim Application (L) No. 32198 of 2025 in

Com. I.P. Suit (L) No. 32130 of 2025 (Bombay High Court) (paragraph nos. 11,

14, 15 and 18).

16. On this basis, Dr. Saraf submits that the Plaintiff is entitled to protection

of facets of his personality, such as his name, screen name, image, likeness, voice,

and signature, against unauthorized exploitation by third parties. Based on the

aforesaid submissions, Dr. Saraf has pressed for urgent interim reliefs on an ex

parte basis, relying on the averments detailed in paragraphs 82 and 86 to 88 of

the plaint. He further submits that issuing notice to the Defendants would

precipitate the harm the present application seeks to prevent, as it would

provide them with an opportunity to inflict further harm and damage upon the

Plaintiff's rights and reputation. In such an event, the entire purpose of the

present interim application would be delayed and defeated.

17. Lastly, Dr. Saraf emphasized that Rule 3(1) of the Information Technology

(Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, requires

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social media intermediaries to exercise due diligence and undertake reasonable

efforts to ensure users do not host, display, modify, publish, transmit, store,

update, or share any information that is obscene, deceives or misleads the

addressee, or impersonates another person. Therefore, Defendant Nos. 2 (Meta

Platforms, Inc.), 3 (X Corp.), 4 (Google LLC), and others possess the requisite

authority to restrict the circulation of infringing content that violates the

Plaintiff's personality rights.

18. Having perused the material on record, I must note that what is truly

alarming in a number of these cases is the realistic nature of deepfake

images/videos that are being created by using AI. Both in the context of images

and videos, the morphing is so sophisticated and deceptive that it is virtually

impossible to discern that the same are not genuine images/videos of the

Plaintiff. The deepfake video of the Plaintiff making communally inflammatory

statements and statements about Rishi Valmiki is deeply concerning. The

consequences that can arise from such content being disseminated are indeed

most grave and serious. Apart from violating and affecting the Plaintiff's

personality and moral rights, such videos also pose a grave threat to the safety

and well-being of the Plaintiff's family members and can also have an adverse

and widespread impact on society and public order, which clearly appears to be

the agenda of those who create such content. Hence, such content needs to be

removed from the public domain immediately, not only in the interest of the

Plaintiff but also in the larger public interest.

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19. Additionally, the material on record discloses the egregious nature of the

infringing material, particularly (i) the creation and dissemination of AI-

generated morphed photos/deepfakes/videos depicting the Plaintiff; (ii) the

unauthorised offering of services (including through AI) infringing upon

Plaintiff's persona; (iii) the unauthorised sale of merchandise/goods infringing

upon Plaintiff's persona, inter alia, using images or AI-generated images of the

Plaintiff; (iv) the unauthorised/unlawful use or infringement of the Plaintiff's

persona, being specially set forth in paragraph nos. 46 to 55 and in Exhibits "F",

"G", and "H" of the plaint. The fact that the Plaintiff is an individual who is a

renowned film actor and public personality is adequately set out in the Plaint.

There can be little doubt about the fact that the Plaintiff is a renowned actor and

that the Plaintiffs personality including his name, screen name, signature, image,

likeness, voice and tone, distinctive performance, appearance, and mannerisms,

have become uniquely identifiable with him in the minds of the public. It is

submitted that the Plaintiff possesses an inherent and enforceable right to

control, protect, and commercially exploit his personality, and that any

unauthorised use or misappropriation thereof constitutes not only a violation of

his personality/publicity rights but also his fundamental rights, as enshrined

under the Constitution of India.

20. Hence, in my view, a case for granting the Plaintiff ex parte ad interim

relief is made out. Given the gravity and potential for irreversible harm and

injury, as apparent from what is set out above, I find that the grant of injunction

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would be defeated by the delay of issuing notice, and thus, the present case

warrants the immediate grant of ex parte interim reliefs.

21. I find merit in the submissions advanced by Dr. Saraf that, in addition to

the identifiable infringers, there exist several other entities whose identities are

presently unknown, concealed, or difficult to trace. Considering the clandestine,

pervasive, and continuing nature of these infringing activities and the persistent

harm being caused, the Plaintiff has rightly impleaded Defendant No. 1 (John

Doe) to collectively represent such unidentified persons.

22. In view of the aforesaid, I grant the Plaintiff ex parte interim relief as

follows:

(a) Pending the hearing and final disposal of the Interim Application,

Defendant Nos. 1, 8 - 13 and 16 - 17 by themselves, their agents,

servants, associates, and/or any person claiming through or under them,

shall be restrained from violating the rights of the Plaintiff:

(i) By infringing and/or utilizing and/or misappropriating the

Plaintiff's personality rights and/or moral rights in any manner,

directly or indirectly using and/or exploiting and/or imitating any

of the Plaintiff's indicia, namely: (i) the name including Plaintiff's

Screen Name "Akshay Kumar" and any abbreviation, moniker or

variation thereof; (ii) voice; (iii) image; (iv) likeness; (v) distinctive

performance, appearance and mannerisms; and (vi) signature and

any other uniquely identifiable attribute on any medium and in

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any manner whatsoever including through Artificial Intelligence

generated content, deepfake videos, voice cloned audio, edited or

morphed visuals, metaverse environments and any future formats

or mediums.

(ii) By passing off their goods, services, schemes, content, promotions,

or advertisements as emanating from, endorsed by, or associated

with the Plaintiff by use of any of his indicia, namely: (i) the name

including Plaintiff's Screen Name " Akshay Kumar" and any

abbreviation, moniker or variation thereof; (ii) voice; (iii) image;

(iv) likeness; (v) distinctive performance, appearance and

mannerisms; and (vi) signature and any other uniquely identifiable

attribute on any medium and in any manner whatsoever.

(iii) By importing, manufacturing, warehousing, selling, offering for

sale, advertising, or otherwise dealing in any goods or services,

including counterfeit merchandise, or operating any schemes or

content that exploit the Plaintiff's indicia, namely: (i) the name

including Plaintiff's Screen Name " Akshay Kumar" and any

abbreviation, moniker or variation thereof; (ii) voice; (iii) image;

(iv) likeness; (v) distinctive performance, appearance and

mannerisms; and (vi) signature and any other uniquely identifiable

attribute on any medium and in any manner whatsoever.

(b) Pending the hearing and final disposal of the Interim Application,

Defendant Nos. 1, 8 - 13 and 16 - 17, by themselves, their agents,

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servants, associates, and/or any person claiming through or under them,

are directed to forthwith remove, delete, take down, suspend, and disable

access to the Infringing Content (more particularly set out in paragraphs

46 to 54 and Exhibits F to H of the present Application) and/or content

similar or identical to the Infringing Content that misuses the Plaintiff's

indicia, namely: (a) the name, including Plaintiff's Screen Name " Akshay

Kumar" and any abbreviation, moniker, or variation thereof; (b) voice; (c)

image; (d) likeness; (e) distinctive performance, appearance, and

mannerisms; and (f) signature and any other uniquely identifiable

attribute on any medium in any manner whatsoever, including but not

limited to physical or virtual mediums such as websites, social media, etc.

(c) Pending the hearing and final disposal of the Interim Application,

Defendant Nos. 2, 3, and 4 are directed to take down/remove/disable

access to all listings/pages/content identified as Infringing Content (more

particularly set out in paragraphs 46 to 55 and Exhibits F to H of the

present Application) which exploit/misuse the Plaintiff's indicia, namely:

(a) the name, including Plaintiff's Screen Name " Akshay Kumar" and any

abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d)

likeness; (e) distinctive performance, appearance, and mannerisms; and

(f) signature and any other uniquely identifiable attribute within a period

of one week from the date of receipt of this order.

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(d) Pending the hearing and final disposal of the Interim Application,

Defendant Nos. 2, 3, and 4 are directed to take down/remove/disable

access to any further infringing listings/pages/content of a similar nature

to the Infringing Content (more particularly set out in paragraphs 46 to

55 and Exhibits F to H of the present Application) appearing on their

portal/platforms/websites, upon being notified by the Plaintiff or by his

authorized representative in writing, which exploit/misuse the Plaintiff's

indicia, namely: (a) the name, including Plaintiff's Screen Name " Akshay

Kumar" and any abbreviation, moniker, or variation thereof; (b) voice; (c)

image; (d) likeness; (e) distinctive performance, appearance, and

mannerisms; and (f) signature and any other uniquely identifiable

attribute, subject to their right to communicate to the Plaintiff, with

reasons, any objection to such removal.

(e) Defendant Nos. 5 to 7 are directed to take down/remove/disable access to

all listings/pages/content identified as Infringing Content (more

particularly set out in paragraphs 46 to 55 and Exhibits F to H of the

present Application) which exploit/misuse the Plaintiff's indicia, namely:

(a) the name, including Plaintiff's Screen Name " Akshay Kumar" and any

abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d)

likeness; (e) distinctive performance, appearance, and mannerisms; and

(f) signature and any other uniquely identifiable attribute within a period

of one week from the date of receipt of this order.

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(f) Defendant Nos. 5 to 7 are directed to take down/remove/disable access to

any further infringing listings/pages/content of a similar nature to the

Infringing Content (more particularly set out in paragraphs 46 to 55 and

Exhibits F to H of the present Application) appearing on their

portal/platforms/websites, upon being notified by the Plaintiff or by his

authorized representative in writing, which exploit/misuse the Plaintiff's

indicia, namely: (a) the name, including Plaintiff's Screen Name " Akshay

Kumar" and any abbreviation, moniker, or variation thereof; (b) voice; (c)

image; (d) likeness; (e) distinctive performance, appearance, and

mannerisms; and (f) signature and any other uniquely identifiable

attribute, subject to their right to communicate to the Plaintiff, with

reasons, any objection to such removal.

(g) Defendant Nos. 2 to 7 are directed, upon request and subject to any

restrictions, to furnish to the Plaintiff the basic subscriber/seller

information in their possession (including name, address, email ID,

contact number, IP logs, registration details, and payment details) of the

sellers/uploaders of the infringing listings/content so notified, to enable

the Plaintiff to either implead them as parties to the present proceedings

or place their relevant details before the Court in instances where found

necessary.

(h) Defendant Nos. 18 & 19 are directed, upon request, to furnish to the

Plaintiff the registration details of the domain names for the websites

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available at https://www.jammable.com/akshay-kumar-v2-Iw5eq and

https://beta.opedia.ai/u/akshay-kumar/; including the IP address and the

person in whose name the same is registered. Thereafter, the Plaintiff

shall be at liberty to take such further steps as it may deem fit and proper

in the circumstances.

25. The Advocates for the Plaintiff shall serve notice of this Order on the

Defendants forthwith and file an Affidavit of Service on the next date.

26. Compliance with Order XXXIX Rule 3 of the Code of Civil Procedure,

1908 is permitted by email, considering the large number of Defendants and the

fact that for some Defendants, contact details are not known to the Plaintiff.

Insofar as those Defendants for whom postal addresses are available, the Plaintiff

shall, in addition to service by email, effect compliance by speed post service.

The said compliance shall be done within three weeks of this order being made

available.

27. List on 12th November 2025.

(ARIF S. DOCTOR, J.)

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