Summary
A suit was filed by Sonakshi Sinha before the Delhi High Court alleging unauthorised use of her name, image, voice, and likeness by AI chatbot platforms and e commerce websites. It was observed that AI generated content and merchandising created false endorsement impressions and included objectionable material. A prima facie case was found and an ex parte ad interim injunction was granted restraining exploitation of her persona and directing takedowns within 36 hours. Prior Delhi High Court decisions on personality rights and the right of endorsement were referred to.
Background
The Plaintiff, Sonakshi Sinha, filed a suit before the Delhi High Court against multiple defendants, including AI chatbot platforms and e-commerce websites, alleging unauthorized use of her personality attributes.
The grievance concerned the use of the Plaintiff’s name, image, voice, and likeness to:
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- create AI chatbots impersonating her personality;
- generate objectionable content; and
- falsely promote goods by suggesting her endorsement.
The platforms allegedly enabled users to interact with chatbots representing the Plaintiff, including generating responses attributed to her persona.
Plaintiff’s Contentions
The Plaintiff submitted that:
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- She has enforceable publicity and personality rights in her name, likeness, voice, and other identifiable attributes.
- The defendants were using these attributes without authorization for commercial purposes, including sale of apparel and jewellery.
- AI-generated outputs included objectionable and obscene material, affecting her reputation.
- The use of her persona created a false impression of endorsement, misleading consumers.
- It was also submitted that no consent or license had been granted for such uses.
Court’s Observations
The Court noted that:
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- The Plaintiff is a well-known public figure with established goodwill.
- The material on record indicated use of her persona without authorization, including through AI-generated chatbots.
- Certain content generated through these platforms was objectionable in nature and capable of causing harm to reputation.
- Unauthorized use of celebrity attributes affects both commercial interests and personal rights, including the Plaintiff’s right to privacy and live with dignity.
- The Court referred to prior decisions recognizing a celebrity’s right of endorsement as well as the protection of personality rights in similar contexts.
Interim Relief
The Court found a prima facie case and granted an ex parte ad interim injunction, directing that:
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- Defendants shall not use or exploit the Plaintiff’s name, image, voice, likeness, or any other identifiable attribute without authorization, including through AI technologies such as chatbots and deepfakes.
- Defendants are also restrained from selling unauthorized merchandise and/or other articles using the elements and attributes of Plaintiff’s persona.
- The identified infringing content and URLs are to be taken down within 36 hours.
Relevant Paras
Para 48: “…I am of the prima facie view that Defendants No.1 to 17 are unlawfully and illegally exploiting and using various elements of Plaintiff’s persona such as her likeness, voice, image etc. for unlawful and unjustified commercial gains, without her consent and/or authorization. Some of these infringers are also hosting images of the Plaintiff with inappropriate clothing and obscene content using AI tools, which is causing irreparable damage to her reputation. As for images showing the Plaintiff as a brand endorser of the merchandise, the additional concern is that if the goods turn out to be of inferior quality, it would be a further debasement of Plaintiff’s goodwill and reputation. In case of Anil Kapoor v. Simply Life India, 2023 SCC Online Del 6914, this Court has held that a celebrity’s right of endorsement acts as a major source of livelihood which cannot be destroyed by permitting unlawful dissemination as sale of merchandise or other articles, bearing the faces or other attributes
of their persona, without their lawful authorization.”
Para 49: “Personality rights have been recognised by this Court in several orders passed from time to time. Plaintiff has a right to protect her name, likeness and all other attributes of her personality and no third party has a right to use these attributes without her consent/authorization. In Jaikishan Kakubhai Saraf v. Peppy Store and Others, 2024 SCC OnLine Del 3664 and Aishwarya Rai Bachchan v. Aishwaryaworld.com and Others, 2025 SCC OnLine Del 5943, this Court held that when attributes of famous personalities are used unauthorisedly, it leads not only to commercial detriment but also impacts his/her rights to privacy/personality and live with dignity…”
Case Citation: Sonakshi Sinha vs Character Technologies Inc & Ors., CS(COMM) 275/2026, decided on 20 March 2026.
Authored by Ms. Benita Alphonsa Basil and reviewed by Mr. Gaurav Mishra.