Khamosh! Bombay High Court Protects Shatrughan Sinha's Catchphrase, Personality Rights
The Bombay High Court has granted an ex parte ad-interim injunction to veteran actor and politician Shatrughan Sinha, restraining the unauthorised commercial exploitation of his personality rights.
The Court also restrained use of his signature catchphrase “Khamosh” and his distinctive vocal mannerisms, observing that the expression, delivered in his unique and distinct style, is associated exclusively with his persona.
Justice Sharmila U. Deshmukh on February 16, 2026, stated that Sinha's name, likeness, and iconic attributes, including his unique delivery of the word “Khamosh,” deserve legal protection from infringement, particularly through modern technologies like Artificial Intelligence.
The lawsuit was filed by Sinha seeking to restrain various defendants, including unidentified persons (John Doe), social media platforms, and e-commerce sites, from the continuing unauthorized use of his persona.
Counsel for Sinha submitted that the actor is a renowned artist whose screen persona earned him the nickname “Shotgun” and that his unique manner of delivering the term “khamosh” has become inseparably associated with him as one of Indian cinema's most memorable expressions.
The plaintiff's submissions highlighted several disturbing trends, including the creation of fake profiles impersonating Sinha on social media. This included unauthorized sale of merchandise using his image, photograph, and signature. The use of AI-generated deepfakes, face morphing, and pornographic content which allegedly tarnished his reputation and professional standing were also presented before the court
In its prima facie observations, the Court noted, 'Shatrughan Sinha is well-known and renowned actor and apart from having substantial body of work in the Hindi film industry, which is marked with various awards and recognition being bestowed for his work and performance, is also actively involved in national and regional politics. The Plaintiff has also contributed to many social and welfare issues.”
The Court traced the protection of these rights to provisions of passing-off under the Trade Marks Act, 1999, and moral rights under the Copyright Act, 1957. Citing the Delhi High Court's decision in Arun Jaitley vs. Network Solutions, the Court agreed that a personal name, when distinctive due to popularity, fulfills the criteria of a trademark.
Regarding Sinha's signature catchphrase, the Court observed, “It needs no reinforcement that the expression 'Khamosh' which was delivered by the Plaintiff in his unique and distinct style... is associated exclusively with the Plaintiff's persona”.
The Court also addressed the misuse of Artificial Intelligence and generative AI. The Court found that using AI to morph of Sinha's face and create digital forgeries results in a violation of personality rights for which there is no justification.
The injunction restrains the defendants from using Sinha's name, vocal mannerisms, catchphrase, or image for commercial or personal gain without authorization. It restrains them from creating or disseminating deepfakes, GIFs, or face-morphed content on any medium, including the Metaverse and social media. Passing off goods or services as being endorsed by Sinha is also restrained.
The court directed social media and e-commerce platforms to disclose basic subscriber information (BSI), including IP logs and payment details, of the sellers or uploaders of the infringing content.
The ad-interim relief will continue until the next hearing, which is scheduled for March 30, 2026.
For Shatrughan Sinha: Advocates Hiren Kamod, Nidhi Singh, Abha Shah and Amisha Upadhyay i/b India Law