Aishwarya Rai Bachchan v. AishwaryaWorld.com & Ors. : Delhi High Court Strengthens Celebrity Rights Against Deepfakes

Background and significance of the case

On 9 September 2025, the Delhi High Court issued an interim injunction in the matter of Aishwarya Rai Bachchan v. AishwaryaWorld.com & Ors.

The claimant, a world-renowned actress, alleged the unauthorised exploitation of her name, image, likeness, and voice, including through deepfake videos, chatbots impersonating her persona, and the marketing of unauthorised merchandise.

This decision is of particular interest because such cases remain relatively rare. It follows the well-known Anil Kapoor case, decided by the same Court in 2023. Together, these decisions confirm an emerging body of case law on the protection of personality rights in the digital era.

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Facts and allegations

The claimant complained of several types of unlawful uses:

• a website falsely presented as her “official site”;
• the sale of merchandise (T-shirts, mugs, etc.) bearing her image without authorisation;
• the dissemination of manipulated videos placing her in inappropriate or degrading situations;
• the creation of a chatbot impersonating her, including the generation of sexually explicit conversations.

These practices, according to the claimant, amounted to a deliberate strategy to misappropriate her celebrity persona and to mislead the public into believing that she endorsed or authorised such activities.

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Legal grounds invoked

The Court was seized on the basis of several claims:

• Personality rights / publicity rights: the claimant argued that her identity, likeness and voice enjoy distinct recognition and commercial value, and that unauthorised use infringes both her dignity and her economic interests (notably endorsement contracts);
• Copyright and performers’ rights: the reuse of photographs, stills and other protected content aggravated the unlawful appropriation;
• Passing off and unfair competition: the unauthorised websites and merchandise were likely to cause confusion as to source or affiliation;
• Intermediary liability: orders were sought against platforms to remove infringing content and to disclose subscriber information enabling identification of those responsible.

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The Court’s decision

The Court granted an ex parte interim injunction prohibiting all defendants from using, in any manner — including by means of artificial intelligence or deepfake technologies — the claimant’s name, likeness, voice or image, whether for commercial or personal purposes.

The Court further:

• ordered the removal of infringing content within 72 hours;
• directed platforms to disclose identifying information of the operators within 7 days;
• requested Indian authorities to block access to infringing URLs.

The Court held that the dissemination of deepfakes and chatbots impersonating the claimant not only caused an economic loss but also amounted to an irreparable injury to her dignity and reputation.

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Key legal issues

This case raises several important questions:

• the scope of personality rights in the face of generative AI technologies;
• the balance between freedom of expression (satire, parody, commentary) and the protection of dignity and reputation;
• the extent of platforms’ duties when hosting or transmitting infringing content, including obligations to remove and disclose user data.

By expressly referring to the Anil Kapoor case, the Court emphasised that a celebrity’s persona constitutes both a moral and an economic asset, and that parasitic commercial appropriation cannot be tolerated.

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This case constitutes a significant development in the judicial protection of celebrities against AI-generated misuse of their image. Indian courts are positioning themselves at the forefront of this evolving field, adopting firm and practical measures both against direct infringers and against intermediaries.

One may reasonably expect similar claims to multiply, not only in India but also in jurisdictions such as the United States, where the right of publicity is well established, and in Europe, where image rights and unfair competition law may provide effective remedies.

The Aishwarya Rai Bachchan case illustrates how courts are beginning to adapt the law to a new phenomenon: the artificial fabrication of identity through AI.

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Disclaimer: This article is written by a French lawyer. For a more in-depth analysis of the applicable Indian law, consultation with an Indian-qualified lawyer is recommended.