Indian cricketer Abhishek Sharma has approached the Delhi High Court seeking protection of his personality rights against the alleged unauthorised use of his name, image, likeness and identity on digital platforms.
The matter came up before the single-judge Bench of Justice Jyoti Singh, which briefly heard the parties but declined to grant interim relief after finding discrepancies in the material placed on record. The Court adjourned the matter to July 9 and directed Sharma to file an additional affidavit placing on record screenshots of the allegedly infringing URLs that correctly correspond with the tabulated list and annexures filed along with the plaint.
During the hearing, the Court observed that the screenshots relied upon by the plaintiff did not match the URLs and documents annexed with the suit. Justice Singh noted that the inconsistencies in the record made it impossible to examine the alleged infringement and pass an effective interim order. The Court clarified that it was not expressing any disinclination to grant relief but emphasised that judicial directions for takedown of online content could not be issued without complete and accurate supporting material.
Sharma sought removal of several allegedly infringing posts, including AI-generated and digitally manipulated content circulating on social media platforms, contending that such material amounted to unauthorised exploitation of his personality rights, misrepresented his identity and harmed his reputation.
Appearing for Meta, Advocate Varun Pathak submitted that two of the eight URLs identified by Sharma were no longer accessible. He further argued that one of the remaining URLs appeared to contain paparazzi content and did not prima facie constitute a violation of personality rights.
Sharma’s counsel disputed the submission and contended that the impugned content was not an ordinary paparazzi photograph but an AI-generated manipulation of an original image.
According to the plaintiff, a genuine photograph of Sharma with his manager had allegedly been altered using artificial intelligence to falsely portray the manager as his girlfriend, thereby creating a misleading and sensational narrative. It was argued that the content constituted a deepfake-like manipulation intended to distort the context of the original image and unlawfully exploit Sharma’s identity and public image.
While hearing the rival submissions, the Court made important observations on the evolving jurisprudence relating to personality rights in the digital era. Justice Singh observed that disputes involving online content often reveal a thin line between defamation and personality rights, noting that both causes of action may overlap where manipulated or misleading content affects an individual’s reputation while simultaneously exploiting his identity without authorisation.
Responding to the Court’s observations, Meta submitted that false or objectionable statements about an individual would ordinarily fall within the domain of defamation or privacy rather than personality rights. It was further argued that expanding the scope of personality rights to cover all adverse online content would impose an impractical obligation on intermediaries.
Meta pointed out that while Sharma had initially identified around 25 allegedly infringing URLs, the number had subsequently increased to nearly 4,000, making compliance increasingly difficult. According to the platform, accepting such a broad interpretation would effectively require intermediaries to remove large volumes of online content irrespective of whether it actually infringed personality rights.
The proceedings form part of a growing body of litigation before the Delhi High Court concerning protection of celebrity personality rights against the unauthorised commercial exploitation and AI-enabled misuse of their names, photographs, likenesses and identities. The increasing use of AI to generate deepfakes and digitally manipulated images has led several public figures to seek judicial intervention to restrain the circulation of misleading online content.
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