Indian celebrities are securing John Doe orders from high courts to protect their personality rights against AI deepfakes, voice cloning, and unauthorised commercial exploitation. Here is what John Doe orders are and which celebrities have obtained them.

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Artificial intelligence can now clone a celebrity’s voice in seconds. Deepfake technology can superimpose their face onto any video. E-commerce platforms sell merchandise bearing their images without consent. And anonymous websites use their names to peddle fraudulent schemes.

This is the reality that has driven a wave of celebrities, from Bollywood actors to spiritual leaders to cricketers, to approach High Courts across India seeking protection of what the law calls “personality rights.”

The legal weapon of choice has been the John Doe order. For those unfamiliar with the term, a John Doe order is an injunction issued against unidentified or unknown defendants.

The name derives from the Anglo-American legal tradition where “John Doe” serves as a placeholder for an unknown party, much like “Ashok Kumar” does in Indian courts.

What makes these orders particularly powerful is that they apply not just against known infringers but against the world at large, including future infringers who may emerge. When a new website surfaces tomorrow selling fake merchandise with a celebrity’s face, the celebrity does not need to file a fresh lawsuit. The existing order already covers it.

The trend began in November 2022 when veteran actor Amitabh Bachchan approached the Delhi High Court. He alleged that mobile applications, websites, and WhatsApp messages were monetising his images and likeness without permission. Some were using his photographs to promote lottery schemes. Others had created ringtones using his iconic dialogues.

Justice Navin Chawla, hearing the case, passed what would become India’s first blanket John Doe order for personality rights. The court restrained not just the named defendants but the world at large from misusing Bachchan’s name, voice, image, likeness, and his unique style of dialogue delivery.

The order directed the Department of Telecommunications and the Ministry of Electronics and Information Technology to ensure that service providers remove infringing content and block phone numbers used to circulate such messages.

Following that order, more celebrities approached the courts. Within a year, actor Anil Kapoor found himself in a similar predicament. His image was being morphed into pornographic content. Deepfakes were being created using AI. Entities were falsely claiming his endorsement for products he had never heard of.

When he approached the Delhi High Court in September 2023, Justice Prathiba M Singh granted an omnibus ex-parte order restraining 16 named entities and the world at large from misusing not just his name and image, but also his voice, persona, manner of speaking, and even his iconic catchphrase “Jhakaas.”

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Justice Singh noted that technological tools now freely available make it possible for anyone to “use, produce or imitate any celebrity’s persona, by using any tools including Artificial Intelligence.” She held that dilution, tarnishment, and blurring are all actionable wrongs that the plaintiff deserved protection against. The court also directed MeitY to issue blocking orders against pornographic content using morphed images of the actor.

The Anil Kapoor order was significant for another reason. It explicitly addressed the threat posed by AI, something the Amitabh Bachchan order had not done in as much detail. This recognition of AI as a distinct threat would become a recurring theme in subsequent cases.

In May 2024, Jackie Shroff, known for his distinctive style and the phrase “Bhidu”, discovered that AI chatbots were using his persona without authorisation. E-commerce websites were selling merchandise with his images. YouTube videos were distorting his content.

Justice Sanjeev Narula of the Delhi High Court granted protection, restraining defendants from misusing his name, his sobriquets “Jackie” and “Jaggu Dada”, his signature phrase “Bhidu”, his voice, and his image. The court specifically addressed the AI chatbot issue, restraining defendants from commercially using an unlicensed AI chatbot that uses attributes of the plaintiff’s persona.

But Justice Narula’s order was notable for something else as well. Unlike previous orders that granted sweeping protection, he drew a line when it came to freedom of expression. A YouTube video titled “Jackie Shroff Is Savage – Jackie Shroff Thug Life” had compiled clips of the actor’s interviews with animated elements morphed onto his face. Shroff’s lawyers wanted it taken down. Justice Narula refused. He observed that “Thug Life” refers to a determined and resilient attitude to succeed in life despite adversity, and that the video could arguably be viewed as a tribute to Shroff’s assertive demeanour.

Restricting such creative expressions, the court warned, could stifle freedom of expression and deter the public from exercising their right to free speech. This distinction between personality rights and freedom of expression has featured in subsequent cases as well.

Beyond Bollywood: Spiritual leaders, singers, and the AI threat

By 2025, the cases were no longer limited to Bollywood actors. Spiritual leader Sadhguru Jaggi Vasudev, founder of the Isha Foundation, discovered that rogue websites were using AI to create deepfake videos of him endorsing products and schemes he had nothing to do with. When he approached the Delhi High Court in May 2025, Justice Saurabh Banerjee passed what he termed a “dynamic+ injunction”, an evolved form of protection that anticipates future infringements.

The court’s observations captured the urgency of the problem. Justice Banerjee warned that if such misuse is allowed to continue, it will “spread like a pandemic with wide uncontrollable repercussions.” He also acknowledged a challenge: these “hydra-headed” websites, even if blocked or deleted, have the potential to resurface as mirror sites with only minor changes, making it virtually impossible to locate their operators.

A few months later, Sri Sri Ravi Shankar, founder of the Art of Living, faced a similar situation. Deepfake videos had surfaced on Facebook and other websites falsely depicting him endorsing Ayurvedic remedies for diabetes, haemorrhoids, and chronic knee pain. According to the plaintiff, the videos falsely claimed he had conducted years of research or discovered these remedies during meditation.

Justice Manmeet Pritam Singh Arora, hearing the case, granted a John Doe order and directed Facebook’s parent company Meta to remove infringing content within 36 hours. Domain registrars were ordered to suspend and lock the identified websites within 72 hours.

September 2025 saw a flurry of cases. Actress Aishwarya Rai Bachchan approached the Delhi High Court after discovering that a website called AishwaryaWorld was falsely claiming to be her “One and ONLY Authorized & Official Website.” E-commerce platforms were selling t-shirts, coffee mugs, and posters with her image.

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The court also noted that an AI chatbot named “Aish” had been created with a persona that was inappropriate and objectifying. Justice Tejas Karia granted a John Doe order protecting her from unauthorised deepfakes, AI-generated content, and exploitation of her image and initials “ARB.”

Filmmaker Karan Johar sought protection not just for his name and image, but also for his well-known acronym “KJo” and his signature way of saying goodbye, “toodles.” The court granted protection for “KJo”, holding that a celebrity is entitled to safeguard his interest against any misuse of personality attributes. The question of “toodles” was reserved for a later hearing.

Legendary playback singer Asha Bhosle approached the Bombay High Court against two US-based AI companies who were offering voice models that could clone her distinctive singing style. Justice Arif Doctor granted ad-interim protection, holding that making AI tools available to convert any voice into that of a celebrity without permission would constitute a violation of personality rights. Such technological exploitation, the court observed, facilitates unauthorised appropriation and manipulation of a celebrity’s voice, which is a key component of their personal identity and public persona.

The most recent significant order came in February 2026, when singer Jubin Nautiyal approached the Delhi High Court. He alleged that AI platforms were creating voice clones, deepfakes were circulating, and merchandise was being sold without authorisation. Justice Tushar Rao Gedela granted the interim protection, observing that the “dent and damage to the image and personality of the plaintiff, prima facie, appears to be real and present.”

Why Delhi? The jurisdiction question courts are now asking

But Justice Gedela also raised a question about territorial jurisdiction: why are celebrities from across India approaching the Delhi High Court? Nautiyal is based in Uttarakhand. The defendants included entities in Romania and the UAE. “Why are you here?” Justice Gedela asked. “What is accessible here is accessible there. The courts there aren’t abolished yet.”

When Nautiyal’s counsel argued that MeitY and the Department of Telecommunications are headquartered in Delhi, Justice Gedela termed this reasoning as “irrelevant.” “Your concern is infringement. Not implementation. They are only for compliances. You don’t have anything against them,” he observed.

The counsel cited precedents of other celebrities approaching the Delhi High Court, but Justice Gedela observed that those were all interim orders under Order 39 Rules 1 and 2 of the Code of Civil Procedure. “Will that create a precedent?” he asked. Despite these observations, the court granted the interim order, but the question of maintainability in Delhi remains under consideration.

This jurisdictional question is significant because it concerns how personality rights litigation will develop in India. If celebrities from any state can approach the Delhi High Court simply because central ministries are located there, the Delhi High Court could become the default forum for all such cases. Justice Gedela’s observations indicate that this question remains open for consideration.

The legal gap: Why India has no personality rights law

Beyond the jurisdiction question, there is a more fundamental issue. India has no dedicated statute for personality rights. Unlike countries such as the United States, which have state-level right of publicity laws, Indian celebrities must rely on a patchwork of legal provisions.

They invoke Article 21 of the Constitution, arguing that the right to privacy and dignity includes the right to control one’s identity. They cite Article 19(1)(a), arguing that freedom of expression includes the right to control one’s own persona.

They rely on the Trade Marks Act for registered names and signatures, the Copyright Act for performer’s rights, and common law doctrines like passing off, dilution, and tarnishment.

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Passing off, in simple terms, occurs when someone falsely represents their goods or services as being connected to or endorsed by a celebrity. If a website sells weight loss supplements using Amitabh Bachchan’s photograph, creating the false impression that he endorses the product, that is passing off. Dilution is different. It refers to the gradual weakening of a celebrity’s distinctive identity through unauthorised use.

If dozens of businesses start using “Jhakaas” to sell everything from papad to toilet cleaners, the phrase loses its unique association with Anil Kapoor. The distinctiveness gets blurred. Tarnishment is a specific form of dilution where a celebrity’s image is harmed by being associated with offensive or disreputable content, such as when morphed pornographic content is created using their face.

Courts have been applying these doctrines creatively, but the absence of clear statutory guidance means that the law develops case by case, with each judge interpreting the constitutional and common law provisions as they see fit. This has led to generally consistent outcomes, but also to occasional uncertainty about the precise scope of personality rights.

What happens after these interim orders

These orders are interim or ad-interim ex-parte reliefs granted under Order 39 Rules 1 and 2 of the Code of Civil Procedure. They offer temporary protection while suits remain pending. Defendants have not yet had a full opportunity to contest the claims, and final judgments are awaited. As Justice Gedela noted in the Jubin Nautiyal case when counsel cited precedents, these are all interim orders. Whether they will create binding precedent on substantive questions of personality rights law remains to be seen.

The cases keep coming. Coordinate benches of the Delhi High Court have passed orders protecting former cricketer Sunil Gavaskar, actors R Madhavan, Kajol Devgan, NTR Junior and Nagarjuna, journalist Sudhir Chaudhary, podcaster Raj Shamani, Telugu actor Vishnu Manchu, Andhra Pradesh Deputy Chief Minister Pawan Kalyan, and fashion designer Rahul Mishra. Actor Salman Khan has filed a similar suit. Each case adds to the growing body of jurisprudence but also underscores the absence of a comprehensive legislative framework.

Until Parliament enacts dedicated legislation, celebrities will continue approaching courts, and judges will continue applying constitutional and common law principles. The John Doe order has emerged as the preferred interim remedy. As Justice Banerjee observed in the Sadhguru case, if the misuse is not stopped, the wrong message will spread like wildfire with hardly any water left to douse it.

FAQs

What is a John Doe order in Indian law?

A John Doe order is an injunction issued against unidentified or unknown defendants, allowing courts to restrain anonymous infringers from misusing a person’s name, image, voice, or likeness. In India, these orders apply “in rem” — against the world at large — including future infringers who may emerge.

What legal basis do Indian courts use to protect personality rights?

Indian courts rely on Article 21 of the Constitution (right to privacy and dignity) and Article 19(1)(a) (freedom of expression), along with common law doctrines like passing off, dilution, and tarnishment. There is no dedicated statute for personality rights in India.

Can personality rights be inherited after a celebrity’s death?

No. The Delhi High Court in Krishna Kishore Singh v. Sarla A Saraogi & Ors. (2023) held that personality rights, including the right to privacy and publicity, are personal in nature and cease to exist upon death. In this case, the father of late actor Sushant Singh Rajput sought to restrain a film based on his son’s life, but the court refused, holding that these rights cannot be inherited. While living celebrities can protect their identity, heirs cannot assert personality rights posthumously, though they may have recourse to other remedies such as trademark law or passing off.

Are these John Doe orders final judgments?

No, these are interim or ad-interim ex-parte orders passed under Order 39 Rules 1 and 2 of the Code of Civil Procedure, granting temporary protection until the suits are finally decided. The final orders in most of these personality rights cases are yet to be pronounced.