The story so far: The High Court of Delhi issued a notice on January 21, 2026, to actor Salman Khan on an application filed by a China-based AI voice generation platform seeking to vacate an interim injunction protecting the actor’s personality rights. While the main matter was heard on January 23 by the Joint Registrar (Judicial), the Chinese app’s application is listed for February 27.
Who is John Doe?
The original suit named 28 defendants, including major technology companies such as Apple Inc., Google LLC, Meta’s Facebook and Instagram, X, e-commerce platforms including Amazon India and Flipkart, and intermediaries like Telegram FZ LLC. Mr. Khan also sought an injunction against unknown persons, joined as Defendant No. 1 (’John Doe’ or ‘Ashok Kumar’), a procedural device that allows courts to pass ex-parte orders where defendants cannot be identified.
The Chinese AI platform was later added as Defendant No. 35, though it is yet to be formally impleaded following the order of the Joint Registrar (Judicial).
How do personality rights operate?
In K.S. Puttaswamy v. Union of India (2017), the Supreme Court recognised privacy as a fundamental right under Article 21. Courts have since held that unauthorised commercial exploitation of an individual’s persona may infringe the right to life. Personality rights recognise the economic value of identity, particularly for public figures, and are distinct from statutory intellectual property rights.
In a 2025 order involving Aishwarya Rai Bachchan, the Delhi High Court noted that unauthorised use of a celebrity’s identity could cause commercial harm. Courts have restrained false impersonation, unauthorised use of images and names by websites and AI tools, and the creation of manipulated or inappropriate content.
While Article 19(1)(g) guarantees Indian citizens the right to conduct business, this right is subject to reasonable restrictions. Courts have also protected artistic expression, provided such works do not mislead the public or imply endorsement. Foreign entities, however, cannot invoke Article 19 before Indian courts.
What is the Chinese app context?
In 2020, the Union government banned over 200 Chinese applications under Section 69A of the Information Technology Act, citing national security concerns related to data collection and storage. Although the Digital Personal Data Protection Act, 2023, has been passed, enforcement remains pending, leaving gaps in regulation, particularly in the AI sector. Nandan Nilekani recently said voice-based AI is critical for digital equity and could be like a UPI-moment for India. A dismissal of the Chinese platform’s application could have broader implications for misuse by AI companies.
What about fees in celebrity suits?
Personality rights claims are typically filed under the Commercial Courts Act, 2015, since celebrities rarely hold conventional IP rights over their identity. Courts have, however, allowed interim injunctions without upfront payment of court fees in several cases, granting extensions under procedural provisions. This practice has attracted scrutiny, given the high brand valuations often cited in such suits. Recent scrutiny in the European Union of generative AI systems such as Elon Musk’s Grok highlights similar regulatory concerns.
In India, while the IT Rules, 2021 provide takedown mechanisms, the limited effectiveness of grievance redressal systems has pushed public figures to seek relief directly from High Courts. Ensuring protection against digital impersonation from celebrities to citizens remains a pressing concern.
Virag Gupta is an advocate at the Supreme Court.
Curated by James Chen
