Bombay High Court Grants Actor Ananya Panday Protection Against AI-Generated Content, Fake Endorsements

The Bombay High Court has recently granted ad-interim protection to actor Ananya Panday against the unauthorised commercial exploitation of her identity. The alleged misuse includes AI-generated images, fake product endorsements, merchandise bearing her photographs and AI-enabled chatbots impersonating her.

A single-judge bench of Justice Madhav J Jamdar, by an order dated November 5, restrained operators of the identified websites and platforms, along with persons acting through them, from exploiting Panday's personality attributes without her knowledge, authorisation and consent. The court also directed e-commerce and social media intermediaries to remove identified unauthorised product listings and content.

Panday approached the court alleging infringement of her personality and publicity rights, violation of privacy and performer's rights, and passing off.

She alleged that her photographs and identity were being used to sell posters, T-shirts, mugs, calendars, pillows, mouse pads and phone cases without her permission.

One website allegedly allowed users to select her photographs for printing on customised merchandise. Another promoted T-shirts using AI-generated images depicting her wearing the products, falsely suggesting that she had endorsed them.

She also complained of social media content featuring obscene, sexually explicit and manipulated depictions of her. This included AI-generated images and videos.

Certain websites allegedly hosted AI-enabled chatbots that allowed users to interact with digital representations of Panday. These chatbots could generate statements attributed to her, including sexually suggestive, obscene and derogatory content.

Finding a case for interim protection, Justice Jamdar observed that the pleadings and accompanying documents showed that Panday's right to control how her personality attributes were used, depicted, reproduced, communicated to the public or otherwise exploited by third parties had been violated.

“Various averments raised in the plaint and documents annexed to the plaint clearly show that the Plaintiff's right to privacy including her rights of personal autonomy, bodily privacy and dignity and her right to control the use, representation and depiction of the Plaintiff's identity and persona are affected. Her right to privacy is a fundamental right guaranteed under Article 21 of the Constitution of India.”, the court ruled.

“Accordingly, a case is made out for grant of ad-interim injunction,” the court held.

The injunction covers the unauthorised use, reproduction, manipulation and exploitation of Panday's name, image, photographs, likeness, voice, signature, performance style, mannerisms, dialogue delivery and other distinctive personality attributes.

It also restrains the creation and dissemination of objectionable content using artificial intelligence. The restriction extends to AI-enabled chatbots, characters, simulations, and other digital representations purporting to be Panday.

The court directed e-commerce intermediaries to remove or disable access to the identified unauthorised product listings. Social media intermediaries must remove or disable access to the identified content and take reasonable and practicable measures to prevent the continued availability of identical or substantially similar material.

Panday has also been permitted to bring details of additional websites, URLs, domain names, and social media accounts disseminating similar unauthorised content before the court through an appropriate application. She need not institute fresh proceedings for this purpose, though any extension of the injunction will be subject to the court's satisfaction.

The matter will next be heard on December 17, 2026.