It is definitely in the fitness of things that while taking a progressive and nuanced stand, the Bombay High Court in a most learned, laudable, landmark, logical and latest judgment titled Akshay Hari Om Bhatia vs John Doe and Ors in Interim Application (L) No. 33184 of 2025 in Commercial IP Suit (L) No. 32986 of 2025 and cited as 907-IA(L)-33184-2025 (OS).DOC in the exercise of its ordinary original civil jurisdiction in its commercial division that was pronounced just recently on 15.10.2025 and so also was uploaded on 16.10.2025 while granting an ad-interim relief and urgent interim protection to Bollywood actor Akshay Hari Om Bhatia known famously as Akshay Kumar over his personality rights and has restrained certain websites, social media accounts, e-commerce sites, AI content creators and others including John Doe (all unknown persons) from misusing his name, image, likeness, voice and personality rights without his consent or authorization. It must be noted that the Single Judge Bench comprising of Hon’ble Mr Justice Arif S Doctor has minced absolutely just no words to hold in no uncertain terms most unequivocally that the “realistic nature of deepfake images and videos” created with AI was “deeply concerning”, adding that such fabrications not only violated Kumar’s personality and moral rights but also posed a “grave threat” to public order and the safety of his family. So it was but ostensible that he got the much needed relief from Bombay High Court!
We need to note that Akshay Kumar had filed the commercial IP suit seeking to restrain unauthorized exploitation of his personality across digital platforms. It is worth paying attention that the suit invoked Article 21 of the Constitution and the Copyright Act of 1957 to assert his right to privacy, dignity and moral rights. The actor, who has used the screen name “Akshay Kumar” throughout his 35-year film career had rationally argued that deepfakes and AI impersonations had caused serious harm to his reputation and public standing.
What also must be observed is that during the hearing, the senior counsel Birendra Saraf who represented Akshay Kumar in this leading case cited several instances which included a fake movie trailer that falsely depicted Akshay as UP CM Yogi Adityanath which garnered nearly two million views before being taken down and this had led to huge public outrage. Another AI-generated trailer for a non-existent film titled “Mahrishi Valmiki” portraying Akshay Kumar as Maharishi Valmiki that had gone viral online also misled the public and triggered furore and protests in Jalandhar after members of the Valmiki community found the portrayal of their revered saint as “deeply offensive”. It was contended by counsel of Kumar that he was wrongfully implicated in communal disharmony in which he had no intention or knowledge about the same.
Akshay Kumar submitted that such misuse not only infringes upon his right of publicity but also damages his professional reputation, undermines the goodwill built over his career, and harms his genuine upcoming film projects. The Bench conceded that the realistic nature of AI-generated deepfakes made them nearly indistinguishable from genuine footage and was therefore, particularly dangerous. It was in this background that the Bombay High Court, pending final disposal of application also directed other defendant social media platforms to take down and remove access to the infringed material.
The Court will hear the plea next on November 12. It also directed Meta (Instagram, Facebook), X Corp (Twitter) and Google to remove infringing content within one week and to act on future complaints of misuse. We need to bear in mind that Akshay Kumar is the third celebrity who has availed of such a relief from the Bombay High Court within the last three weeks. Earlier, we saw that the Single Judge Bench comprising of Hon’ble Mr Justice Arif S Doctor also protected veteran singer Asha Bhosle and Bollywood actor Suniel Shetty through two interim orders granting similar reliefs. It may be recalled that last year, a Single Judge Bench of Hon’ble Mr Justice Riyaz Chagla had protected the personality rights of eminent singer Arijit Singh.
At the very outset, this brief, brilliant, bold and balanced judgment authored by the Single Judge Bench comprising of Hon’ble Mr Justice Arif S Doctor sets the ball in motion and puts things in perspective by first and foremost putting forth and envisaging in para 1 that, “The Plaintiff has, by way of the present Suit, sought, inter alia, the protection of his personality rights, his right to privacy, and his right to live with dignity as granted under Article 21 of the Constitution of India, and also the protection of his moral rights under the Copyright Act, 1957. The Plaintiff uses the screen name “Akshay Kumar” right from the beginning of his career spanning more than 35 years and has, over the years, been identified by that screen name, “Akshay Kumar”. The Plaintiff asserts that personality rights, his right to privacy, and his right to live with dignity, as well as his moral rights are being infringed and violated through unauthorized use, commercial exploitation, and misrepresentation on social media and e-commerce platforms and across the internet by various entities, some of whom are impleaded as Defendants.”
Most significantly and resultantly, the Bench then encapsulates in para 22 what constitutes the cornerstone of this notable judgment postulating precisely that, “In view of the aforesaid, I grant the Plaintiff ex parte interim relief as follows:
(a) Pending the hearing and final disposal of the Interim Application, Defendant Nos. 1, 8 – 13 and 16 – 17 by themselves, their agents, servants, associates, and/or any person claiming through or under them, shall be restrained from violating the rights of the Plaintiff:
(i) By infringing and/or utilizing and/or misappropriating the Plaintiff’s personality rights and/or moral rights in any manner, directly or indirectly using and/or exploiting and/or imitating any of the Plaintiff’s indicia, namely: (i) the name including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker or variation thereof; (ii) voice; (iii) image; (iv) likeness; (v) distinctive performance, appearance and mannerisms; and (vi) signature and any other uniquely identifiable attribute on any medium and in any manner whatsoever including through Artificial Intelligence generated content, deepfake videos, voice cloned audio, edited or morphed visuals, metaverse environments and any future formats or mediums.
(ii) By passing off their goods, services, schemes, content, promotions, or advertisements as emanating from, endorsed by, or associated with the Plaintiff by use of any of his indicia, namely: (i) the name including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker or variation thereof; (ii) voice; (iii) image; (iv) likeness; (v) distinctive performance, appearance and mannerisms; and (vi) signature and any other uniquely identifiable attribute on any medium and in any manner whatsoever.
(iii) By importing, manufacturing, warehousing, selling, offering for sale, advertising, or otherwise dealing in any goods or services, including counterfeit merchandise, or operating any schemes or content that exploit the Plaintiff’s indicia, namely: (i) the name including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker or variation thereof; (ii) voice; (iii) image; (iv) likeness; (v) distinctive performance, appearance and mannerisms; and (vi) signature and any other uniquely identifiable attribute on any medium and in any manner whatsoever.
(b) Pending the hearing and final disposal of the Interim Application, Defendant Nos. 1, 8 – 13 and 16 – 17, by themselves, their agents servants, associates, and/or any person claiming through or under them, are directed to forthwith remove, delete, take down, suspend, and disable access to the Infringing Content (more particularly set out in paragraphs 46 to 54 and Exhibits F to H of the present Application) and/or content similar or identical to the Infringing Content that misuses the Plaintiff’s indicia, namely: (a) the name, including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance, and mannerisms; and (f) signature and any other uniquely identifiable attribute on any medium in any manner whatsoever, including but not limited to physical or virtual mediums such as websites, social media, etc.
(c) Pending the hearing and final disposal of the Interim Application, Defendant Nos. 2, 3, and 4 are directed to take down/remove/disable access to all listings/pages/content identified as Infringing Content (more particularly set out in paragraphs 46 to 55 and Exhibits F to H of the present Application) which exploit/misuse the Plaintiff’s indicia, namely: (a) the name, including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance, and mannerisms; and (f) signature and any other uniquely identifiable attribute within a period of one week from the date of receipt of this order.
(d) Pending the hearing and final disposal of the Interim Application, Defendant Nos. 2, 3, and 4 are directed to take down/remove/disable access to any further infringing listings/pages/content of a similar nature to the Infringing Content (more particularly set out in paragraphs 46 to 55 and Exhibits F to H of the present Application) appearing on their portal/platforms/websites, upon being notified by the Plaintiff or by his authorized representative in writing, which exploit/misuse the Plaintiff’s indicia, namely: (a) the name, including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance, and mannerisms; and (f) signature and any other uniquely identifiable attribute, subject to their right to communicate to the Plaintiff, with reasons, any objection to such removal.
(e) Defendant Nos. 5 to 7 are directed to take down/remove/disable access to all listings/pages/content identified as Infringing Content (more particularly set out in paragraphs 46 to 55 and Exhibits F to H of the present Application) which exploit/misuse the Plaintiff’s indicia, namely: (a) the name, including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance, and mannerisms; and (f) signature and any other uniquely identifiable attribute within a period of one week from the date of receipt of this order.
(f) Defendant Nos. 5 to 7 are directed to take down/remove/disable access to any further infringing listings/pages/content of a similar nature to the Infringing Content (more particularly set out in paragraphs 46 to 55 and Exhibits F to H of the present Application) appearing on their portal/platforms/websites, upon being notified by the Plaintiff or by his authorized representative in writing, which exploit/misuse the Plaintiff’s indicia, namely: (a) the name, including Plaintiff’s Screen Name “Akshay Kumar” and any abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance, and mannerisms; and (f) signature and any other uniquely identifiable attribute, subject to their right to communicate to the Plaintiff, with reasons, any objection to such removal.
(g) Defendant Nos. 2 to 7 are directed, upon request and subject to any restrictions, to furnish to the Plaintiff the basic subscriber/seller information in their possession (including name, address, email ID, contact number, IP logs, registration details, and payment details) of the sellers/uploaders of the infringing listings/content so notified, to enable the Plaintiff to either implead them as parties to the present proceedings or place their relevant details before the Court in instances where found necessary.
(h) Defendant Nos. 18 & 19 are directed, upon request, to furnish to the Plaintiff the registration details of the domain names for the websites available at https://www.jammable.com/akshay-kumar-v2-Iw5eq and https://beta.opedia.ai/u/akshay-kumar/; including the IP address and the person in whose name the same is registered. Thereafter, the Plaintiff shall be at liberty to take such further steps as it may deem fit and proper in the circumstances.”
It is worth noting that the Bench directs in para 25 holding tersely that, “The Advocates for the Plaintiff shall serve notice of this Order on the Defendants forthwith and file an Affidavit of Service on the next date.”
It would be also instructive to note that the Bench then further hastens to add in para 26 directing and holding that, “Compliance with Order XXXIX Rule 3 of the Code of Civil Procedure, 1908 is permitted by email, considering the large number of Defendants and the fact that for some Defendants, contact details are not known to the Plaintiff. Insofar as those Defendants for whom postal addresses are available, the Plaintiff shall, in addition to service by email, effect compliance by speed post service. The said compliance shall be done within three weeks of this order being made available.”
Finally, the Bench then aptly concludes by holding in para 27 that, “List on 12th November 2025.”
Sanjeev Sirohi