Case Title: Karan Johar v. Ashok Kumar / John Doe & Ors.
Citation: 2025 SCC OnLine Del 6108
Introduction
The Delhi High Court granted an ex parte ad interim injunction in favour of filmmaker and television personality Karan Johar. The order protects Karan Johar publicity rights by restraining the unauthorised use of his name, image, voice, likeness, and the widely recognised acronym “KJo.” The ruling strengthens Indian jurisprudence on personality rights and addresses the growing misuse of artificial intelligence tools to create synthetic and misleading content featuring celebrities.
Background of the Dispute
Karan Johar filed the suit seeking a permanent injunction against copyright infringement, performer’s rights violations, misappropriation of personality rights, publicity rights, passing off, tarnishment, damages, and rendition of accounts.
Johar argued that several known and unknown defendants were misusing his identity across digital platforms. According to the suit, they used artificial intelligence to create deepfakes, morphed images, and manipulated audio-video clips that portrayed him in an offensive and humiliating manner.
The alleged infringement also included unauthorised merchandise such as mugs and T-shirts displaying Johar’s name and likeness. In addition, the defendants allegedly created rogue domain names and fake social media accounts to exploit his identity.
Arguments Before the Court
Senior Advocate Rajshekhar Rao, appearing for Johar, argued that public commentary differs from commercial exploitation. He submitted that viral memes and AI-generated content often generate revenue for creators while unlawfully exploiting a celebrity’s identity.
The plaintiff also argued that the nickname “KJo” and the catchphrase “toodles” had acquired a distinct secondary meaning. According to the submissions, both identifiers are closely associated with Johar’s public persona.
Meta Platforms informed the Court that several flagged comments did not appear defamatory. However, the Court independently examined the material before deciding the matter.
Delhi High Court’s Findings
Justice Manmeet Pritam Singh Arora found a prima facie case in favour of Karan Johar. The Court observed that several videos, memes, and social media posts contained abusive language and offensive insinuations.
The Court held that such content exceeded the limits of fair comment. It noted that abusive posts could damage a celebrity’s reputation and reduce the commercial value of their brand.
The Court further recognised that publicity rights have significant commercial value. Therefore, celebrities can seek legal protection against the unauthorised use of their name, image, voice, likeness, and other personality attributes. It also held that refusing interim relief would cause irreparable harm to Johar’s reputation.
At the same time, the Court clarified that the injunction would not prohibit genuine satire or sarcasm. Instead, it targeted commercially motivated misuse of personality rights.
Court’s Directions
The Court restrained the primary infringing defendants and anyone acting on their behalf from using Karan Johar’s name, the acronym “KJo,” his image, voice, likeness, or any other identifiable aspect of his personality for commercial purposes.
The order specifically prohibits the use of Artificial Intelligence, Machine Learning, deepfakes, face-morphing technology, GIFs, and similar tools to exploit Johar’s identity.
The Court also directed Google, YouTube, Meta, X, Pinterest, Giphy, Tenor, Amazon, Etsy, and RedBubble to remove the infringing content within one week.
Further, intermediaries must provide Basic Subscriber Information and IP log details relating to those responsible for creating and distributing the content.
While the Court recognised “KJo” as a protected identifier, it deferred consideration of the catchphrase “toodles” to the next hearing. The matter is scheduled for 19 February 2026.
Significance of the Judgment
The ruling marks another important development in Indian personality rights jurisprudence. It expands protection beyond formal names by recognising the commercial value of a widely known personal acronym such as “KJo.”
The judgment also acknowledges the legal challenges created by AI-generated content. By expressly referring to deepfakes and face-morphing technology, the Court confirmed that existing intellectual property principles can address emerging technological harms.
The decision further reinforces the importance of Karan Johar publicity rights in the digital age. It recognises that a celebrity’s identity has substantial commercial value and deserves protection against unauthorised exploitation.
Conclusion
The Delhi High Court has reinforced that celebrity identity enjoys legal protection when it carries commercial and reputational value. By granting interim relief covering Karan Johar’s name, acronym, image, voice, and likeness, the Court has strengthened safeguards against AI-enabled misuse and commercial exploitation.
The ruling also reminds digital platforms that they must promptly comply with judicial directions to remove infringing content. As the case progresses, it is likely to shape future Indian jurisprudence on personality rights, AI-generated content, and intermediary liability.
