Summary
In the case of Kumar Sanu Bhattacharjee vs Jammable Limited & Ors, the Delhi High Court held that a celebrity's voice is a protectable aspect of their personality. The court observed that use of artificial intelligence to generate content that imitates a celebrity’s voice without consent amounts to personality rights infringement. An interim injunction was granted restraining various defendants from using the plaintiff’s voice, name, image, likeness or persona.
Personality Rights Infringement by AI Platforms Kumar Sanu, a well-known playback singer, filed a suit for permanent and mandatory injunction against various AI companies, websites, social media platforms, and e-commerce sellers. The plaintiff alleged unauthorised use of his personality traits, including his name, voice, image, and likeness. Some defendants generated synthetic audio using artificial intelligence that replicated his voice. Others published videos, images, and merchandise using his persona without consent. The plaintiff claimed that these acts amounted to infringement of his personality rights and sought interim relief.
Questions Before the Court
- Whether a celebrity’s voice is a protectable element of personality rights.
- Whether use of AI to replicate a celebrity’s voice without consent amounts to personality rights violation.
- Whether an interim injunction should be granted to restrain the unauthorised use of a celebrity’s voice and persona.
Plaintiff’s Submissions
- The plaintiff submitted that his name and voice are uniquely associated with him and are instantly recognised by the public.
- AI platforms were generating audio clips that mimicked his voice and vocal style without consent, thereby misleading the public and causing reputational harm.
- The plaintiff further claimed that the unauthorised imitation of his voice and other personal attributes created a false impression of endorsement.
- The plaintiff sought protection of his publicity and personality rights, and requested the court to restrain the infringing acts.
Court’s Analysis of Voice as a Personality Right
The court observed that the plaintiff is a prominent singer who enjoys celebrity status in India. It noted that a celebrity’s name, voice, image, and likeness are distinct personality traits that are entitled to protection. According to the court, the plaintiff’s voice is instantly recognisable and uniquely associated with him. The court held that the unauthorised use of his voice by AI tools to create synthetic audio content amounted to commercial exploitation of his persona without consent.
The court stated that artificial intelligence is being used to imitate the plaintiff’s voice and style, and that such imitation infringes his personality rights. It referred to earlier decisions, including D.M. Entertainment v. Baby Gift House, Anil Kapoor v. Simply Life India, and Jackie Shroff v. The Peppy Store, and observed that publicity rights extend to all identifiable elements of a person’s persona, including voice. The court further stated that the commercial value of a celebrity’s voice cannot be exploited without authorisation, including by replicating the voice through technological means.
Findings
- The court held that the plaintiff’s voice is a protectable element of his personality.
- It granted an interim injunction restraining the defendants from using the plaintiff’s name, voice, likeness, image, and other aspects of his persona through any means, including artificial intelligence.
- The court directed AI platforms, intermediaries, and e-commerce websites to remove infringing content identified in the suit and to act on future takedown requests within 48 hours.
Relevant Paras
“A celebrity is entitled to safeguard his interest against any misuse of the personality attributes which includes his name, image, voice and likeness.” (Para 40)
“Plaintiff’s personality traits and/or parts thereof, including Plaintiff’s name Kumar Sanu, voice, image, photograph or likeness and other attributes are protectable elements…” (Para 41)
“Defendants… are restrained from utilising the Plaintiff – Kumar Sanu’s name, likeness, image, voice, personality or any other aspects of his persona… using technological tools such as Artificial Intelligence…” (Para 49.1)
Case Citation
Kumar Sanu Bhattacharjee vs Jammable Limited & Ors, CS(COMM) 1097/2025, Delhi High Court, decided on 15 October 2025.
Available at: http://indiankanoon.org/doc/129562687/ (Visited on 25 October 2025)
Disclaimer
This case blog is based on the author’s understanding of the judgment. Understandings and opinions of others may differ. An AI application was used to generate parts of this case blog. Views are personal.
