Delhi High Court Protects Personality Rights of Actor R . Madhavan, Orders Take Down of Infringing Content Such as Counterfeit Merchandise, Obscene Pictures, AI-Gene Rated Fake Videos and Social Media Posts
by Anushree Rauta, Shwetank Tripathi, Vidit Desai, Devangini Rai and Purvi Mehta
In the matter of R. Madhavan v G Filmz Studioz & ors, CS(COMM) 1392/2025, the Learned Single Judge of Delhi High Court passed an interim order dated 22 December 2025 protecting the personality rights of the Plaintiff and directing the known and unknown defendants including intermediary platforms to take down the infringing content such as AI generated videos, fake and deceptive film trailers and other social media posts videos, deepfakes, posters and other counterfeit merchandise bearing Plaintiff’s persona and obscene content.
The Plaintiff having come across several material online evincing misuse of his personality rights, filed a suit for injunction against infringement of personality / publicity rights, moral rights under the Copyright Act, 1957 and common law rights against misappropriation. Prior to filing of the suit, the Plaintiff had issued notices through its advocates to the intermediary platforms calling upon them to take down the infringing content and disclose the details of the sellers / uploaders of the infringing content. Pursuant thereto, some of the intermediary platforms complied with the notice while some did not.
The interim application filed along with the suit was taken up for hearing on 22 December 2025 when the Court recognised the Plaintiff’s protectable and enforceable personality / publicity rights and directed the Defendants to take down the infringing content. The Court further directed the intermediary platforms to disclose the details of the sellers / uploaders of infringing content and granted liberty to the Plaintiff to impleaded such sellers / uploaders in the present proceedings. Google and Meta appeared through counsels and objected to taking down of some content, however, the Court observed that the contents being AI-generated and uploaded from commercial accounts, were liable to blocked which were accordingly ordered to be blocked.
The Plaintiff, Mr. R. Madhavan, was represented by Ms. Swathi Sukumar, Senior Counsel, instructed by the law firm ANM Global, through Ms. Anushree Rauta (Equity Partner), Mr. Shwetank Tripathi (Partner Designate), Mr. Vidit Desai (Senior Associate), Ms. Devangini Rai and Ms. Purvi Mehta (Associates), along with Mr. Mohit Bangwal
