As in the case filed by legendary film personality Kamal Haasan, a John Doe order is a type of legal order that allows a person or entity to take legal action against an unknown party or parties. This legal classification is often used when the identity of the person or entity being sued is not known at the time when the legal action is taken.
While it originated in America and Canada, where John Doe is used by police forces to refer to unidentified bodies, in India it is being increasingly used in courtrooms with the spread of deepfakes and artificial intelligence tools. Indian courts sometimes replace John Doe with another eponymous name, Ashok Kumar, but John Doe orders are more commonly employed.
The Oxford Dictionary defines John Doe as an “anonymous party”. If the anonymous defendant is a female, the name “Jane Doe” has known to be used.
In the latest John Doe order relating to the case filed by actor Kamal Kaasan, Justice Senthilkumar Ramamoorthy of the Madras High Court explained: “Senior counsel (for plaintiff) invited my attention to several photographs of morphed images. He submits that these images are causing incalculable damage to his reputation and image as a celebrity. Counsel also refers to the use of plaintiff’s image, name and the like on merchandise without the plaintiff’s consent or endorsement.”
The need for a John Doe order, also known as an Ashok Kumar (in India) or an Anton Pillar order (in Europe), arises when there is rampant infringement or unlawful exploitation such that it is practically impossible for a rights owner to identify all infringing parties. These orders are only passed in specific instances, where the court deems it necessary that it is the only effective measure for a rights owner to enforce such rights against unknown parties.
The majority of cases involve film and media, protecting big-budget movies from being leaked or pirated online prior to or during their theatrical release. Then there are orders restraining the sale of counterfeit goods or unauthorized use of well-known trademarks.
Recent high-profile orders in 2025 and early 2026 have protected the likeness, voice, and name of celebrities from AI-generated deepfakes and unauthorized commercial use (Kamal Haasan being the latest example). There are also such orders instructing social media platforms or Internet Service Providers (ISPs) to take down defamatory content or “John Doe” posts that violate a person’s right to privacy or reputation.
John Doe orders were first employed in India in the case of Taj Television vs Rajan Mandal where the Delhi High Court restrained unlicensed cable operators from unlawfully broadcasting the 2002 FIFA World Cup. They who were illegally transmitting the plaintiff’s channel, infringing on their rights. The Court ruled that the plaintiff was the authorized registered broadcaster of the globally televised event and had suffered revenue loss due to unauthorized and unlicensed transmission of its channel, Ten Sports, by certain unlicensed cable operators. The Court said it was finding it difficult to identify any particular unlicensed cable operators out of thousands of cable operators in India. The Court then historically passed a John Doe/Ashok Kumar order against unidentified cable operators.
Since then, there have been numerous such cases, but it is, in legal terms, an exhaustive process. In order to obtain a John Doe order, the plaintiff must satisfy specific conditions as seen in several such judgments. The plaintiffs need to prove their right in respect of the work sought to be protected, how they obtained such right and verified instances of breach, and more importantly, establish how the infringement will cause irreparable harm and damage to the plaintiff. Some notable John Doe cases are:
ESPN Software India Pvt Ltd vs Tudu Enterprise and Ors
The plaintiff, who had the exclusive right from the International Cricket Council to broadcast all their events till 2015, sought to restrain the defendants from transmitting the 2011 ICC Cricket World Cup without permission.
UTV Software Communications Limited vs Home Cable Network Ltd
The Court granted a John Doe order against the cable operators, who illegally telecast pirated version of films made by the petitioner. The Court agreed with the plea that a single telecast by the defendant would simultaneously reach several hundred thousand homes resulting in losses which could not be computed in terms of money.
Satellite Singapore PTE Ltd vs Star Cable Network
The Delhi High Court in order to check piracy and unauthorised transmission passed orders prohibiting the respondents from broadcasting/using unauthorized signals of the appellant for downloading/telecasting purposes during the Indian Premier League (IPL) cricket tournament.
UTV Software Communications Limited vs Home Cable Network Ltd
A John Doe order was obtained against the cable operators who illegally telecasted pirated version of the films 7 Khoon Maaf and Thank You. In this case a few cable operators were identified, but most remained unidentified, hence the John Doe order. These unidentified cable operators were collectively termed as defendant nos 19 to 50 as “Mr Ashok Kumar”.
Reliance Big Pictures obtained a similar order from the Delhi High Court to prevent the illegal broadcast or streaming of the films Bodyguard and Singham. Reliance Entertainment claimed that this order brought down the piracy of the movie by 30 percent.
Red Chillies Entertainments Private Limited vs Hathway Cable & Datacom Limited
Owned by superstar Shah Rukh Khan, Red Chillies obtained a John Doe order restraining any person from telecasting/ broadcasting/or otherwise making available to the public, the film Happy New Year.
Ardath Tobacco Company Ltd vs Mr Munna Bhai and Ors
An order was passed against unidentified Defendants No 7 to 23 named as “Ashok Kumar”, who were restrained from manufacturing, selling, stocking or dealing in cigarettes under a label, carton or packaging material deceptively similar to the label, carton and packaging material and artistic work of State Express 555 of the plaintiff.
SanDisk Corporation vs John Doe
The Plaintiff had submitted that certain unknown persons were selling counterfeit products with identical name and packaging and logo and it was impossible to identify the sellers. The Court issued an order: “The unnamed and undisclosed persons arrayed as “John Does” are restrained from manufacturing, selling, offering for sale, advertising, directly or indirectly, dealing in counterfeit products, which are identical to the products bearing the plaintiff’s Trade mark SanDisk and logo marks and the “Red Frame” logo, with identical product packaging, product get-up, colour scheme, layout, overall look and feel as that being used by the plaintiff.
Luxottixa Group vs Ashok Kumar
This involved unidentified persons indulging in the manufacture and sale of counterfeit optical units under the trademark of Ray Ban.
The maximum infringement of such original works happens just before the Friday release of films across the country, where pirated copies are made available by numerous John Does or Mr Ashok Kumars. In fact, one major area of controversy surrounding John Doe orders in India is their use in relation to online piracy in cases involving the illegal downloading of movies or music. The potential damage through piracy is huge in terms of losses, whether in movie ticket sales or subscription to a legal music/movie streaming service, leading to infringement of intellectual property rights. However, it can lead to major service providers being blocked, instead of just the offending websites or internet pirates who are almost impossible to identify and block individually.
In order to pass John Doe orders, the Indian courts rely on Order 39, rules 1 and 2 of the Civil Procedure Code, 1908 (CPC) and the provisions of the Specific Relief Act, 1963 related to permanent injunctions. In many cases, it goes beyond just a movie/song or a trademark mannerism, and has the potential to cause serious harm to the image of the celebrity involved. In the latest such John Doe episode involving Kamal Haasan, the actor pointed out that some websites had been selling T-shirts bearing his name and photograph, which would give the impression that it was being authorised by him. He also added that websites were morphing his face into videos and using artificial intelligence to create false and misleading image and videos which were sometimes sexually explicit and vulgar.
With the surge in internet usage in India dubious websites have cropped up. Statistically, India is ranked amongst the top five countries worldwide for piracy. With AI deepfakes proliferating alarmingly, John Doe, or Ashok Kumar, seem certain to mark their presence more frequently in Indian courtrooms. The major challenge, however, is that without clear guidelines, ISPs are put in a difficult position, forced to act as enforcers and potentially censor content without proper vetting.
—The writer is former Senior Managing Editor, India Legal magazine
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