Madras High Court Dismisses Actress Tamanna Bhatia's Rs 1 Crore Damages Claim Against Soap Maker

The Madras High Court has recently dismissed an appeal filed by actress Tamanna Santhosh Bhatia, upholding a single judge's decision rejecting her claim for Rs.1 Crore in damages against soap manufacturer Power Soaps Limited.

By a judgment dated April 16, 2026, a Division Bench of Justices P. Velmurugan and K. Govindarajan Thilakavadi held, “Using an actress photographs on cosmetic products after the expiry of an endorsement agreement constitute a clear violation of her personality rights, right to publicity and right to privacy. Such acts amounts to unauthorized commercial exploitation enabling the actress to file a law suit for damages and permanent injunction."

The court further observed, “However, the burden lies on the plaintiff to produce the best evidence, such as the products themselves showing the photos were used for promoting the products and the defendants have nexus for using the pictures/photos of the actress without her permission after the expiry of the endorsement agreement.”

The appeal arose from the dismissal of her suit against the soap manufacturer and its advertising agency, in which she had sought damages of Rs.1 crore and a permanent injunction restraining use of her photographs, videos or likeness for commercial purposes after expiry of her brand ambassador agreement in October 2009.

According to the actress, she had entered into an agreement dated October 7, 2008, to act as brand ambassador for one year, which expired on October 6, 2009. She alleged that despite refusing to extend the agreement, the company continued to use her photographs in advertisements and product packaging during late 2010 and early 2011.

The company denied the allegations, contending that the suit was speculative and that instructions had been issued to advertising associates not to use the actress's images after expiry of the agreement. It further submitted that any such use could be attributable to counterfeit or third-party infringers for which it was not responsible.

Examining the evidence, the court found that the actress's case relied on documents that failed to establish any purchase of the products or a link between the allegedly infringing wrappers and the company. The court noted that the document relied upon was only an estimate issued to a third party and not proof of purchase and that the witness through whom it was introduced had obtained it from an unexamined person, thereby weakening its evidentiary value.

The bench held that the actress failed to establish any nexus between the wrappers bearing her photographs and the products of the company. It also held that reliance on an online listing was insufficient to show that the company had authorized publication of her photographs.

Holding that the materials relied upon did not constitute concrete evidence, the court concluded that the actress had failed to prove any unauthorized use attributable to the company.

Finding no infirmity in the single judge's decision, the court dismissed the appeal with costs and closed the connected miscellaneous petition.