The Madras High Court has accorded interim judicial protection to renowned music composer Ilaiyaraaja, recognising a prima facie infringement of his personality rights. Justice N Senthilkumar, while issuing an interim injunction, observed that the composer’s identity attributes were being used across digital platforms without his authorisation, thereby amounting to a wrongful commercial appropriation of his persona.
The Court noted that various online entities had engaged in the unauthorised utilisation of Ilaiyaraaja’s name, image, likeness, voice samples, caricatures, animated representations, and artificial intelligence generated visuals. Such acts, the Court held, possess the potential to mislead the public into believing that the composer had endorsed or collaborated with these channels, when no such consent existed.
Senior Advocate S Prabhakaran, appearing for Ilaiyaraaja, submitted that multiple YouTube channels and social media accounts had been circulating morphed videos, memes, and deepfake style content, synchronising the composer’s music with digitally fabricated visuals. This, counsel argued, constituted an illegitimate commercial exploitation of Ilaiyaraaja’s personality and reputational goodwill.
The Court relied on established jurisprudence that affirms the enforceability of personality and publicity rights. It referred to prior judicial pronouncements, including the decision on impersonation through artificial intelligence and the earlier ruling in Shivaji Rao Gaekwad v Varsha Productions, where it was held that the law protects not only the natural likeness of a person but also stylised or animated depictions that evoke their identity.
In light of the submissions and the materials placed on record, the Court concluded that the plaintiff had established a strong prima facie case and that the balance of convenience lay decisively in his favour. Accordingly, an interim injunction was granted restraining the defendants from employing any attribute that directly or indirectly identifies Ilaiyaraaja without securing prior written consent.
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