Constitutional, judicial, comparative and critical foundations of personality, publicity, privacy and dignity rights in India

I. Introduction and Thesis

Personality rights the bundle of interests allowing a person to control commercial and non-commercial use of their name, voice, image, likeness, signature and mannerisms are constitutionally rooted but judicially improvised in India: formally available to every person under Articles 14, 19 and 21, yet litigated almost exclusively by film stars, singers, cricketers and industrialists who can retain senior counsel and obtain ex-parte John Doe injunctions within hours from specialised commercial courts.

This memorandum tests the thesis that Indian personality-rights jurisprudence is “formally universal but practically elitist.” It traces the doctrine from the constitutional right to privacy through its outer limits at the boundary of ideas and fictional characters, through questions of biography and posthumous survival, into celebrity commercial litigation and its AI/deepfake frontier; it asks who can actually enforce the right, examines its collision with free speech, journalism, parody, open justice and its potential use as narrative “leverage,” surveys comparative law, and weighs the counter-risk that universalising the right could itself chill expression and transparency.

A recurring illustration used throughout is the unresolved 2026 public dispute over 3 Idiots’s character Phunsukh Wangdu (‘Rancho’) and his popularly assumed real-world inspiration, Ladakhi educationist Sonam Wangchuk a dispute that usefully separates the historical question of “who inspired whom” from the distinct legal question of when inspiration crosses into actionable appropriation of identity.

II. Constitutional Foundations: Articles 14, 19 and 21

India has no publicity-rights statute; the doctrine is judge-made from three limbs. Article 21: R. Rajagopal v. State of Tamil Nadu, (1994) 6 SCC 632 (‘Auto Shankar’) held the right to privacy implicit in Article 21, including a right “to be let alone” and to control publication of one’s life story, subject to the public-record exception the source of virtually every later personality-rights case. Justice K.S. Puttaswamy (Retd.) v. Union of India, (2017) 10 SCC 1 unanimously affirmed privacy as a fundamental right and recognised “informational self-determination” as inhering in every person, not merely the famous.

Article 19(1)(a)/(g) protects speech (news, biography, satire, parody, criticism) and commercial expression, the peg for the “commercial free speech” defence. Article 14 confers no lesser entitlement on ordinary citizens; the elitism this memorandum tests is therefore practical, not textual arising from evidentiary thresholds (“identifiability,” “commercial value”) and enforcement infrastructure, not the constitutional text.

III. Doctrinal Origins: From Privacy to a Commercial Right of Publicity

• ICC Development (Intl) Ltd. v. Arvee Enterprises, 2003 (26) PTC 245 (Del) publicity rights vest only in individuals, derived from privacy.
• Titan Industries Ltd. v. Ramkumar Jewellers, 2012 SCC OnLine Del 2382 defined publicity right as “control [of] commercial use of human identity”; no proof of confusion required if identifiable.
• D.M. Entertainment v. Baby Gift House, CS(OS) 893/2002 (Del HC 2010) (Daler Mehndi) protected persona in merchandising but cautioned, in obiter, that parody/lampooning falls outside infringement.
• Shivaji Rao Gaikwad v. Varsha Productions, 2015 (62) PTC 351 (Mad) (Rajinikanth) once celebrity status attaches, unauthorised use is actionable without proof of confusion.

All four founding plaintiffs were already exceptionally famous, and the doctrine’s vocabulary identifiability, merchandising, endorsement, commercial value — was commercial from inception, even though its root in Rajagopal was framed in universal privacy language.

IV. Ideas, Fictional Characters and the Limits of Personality Property

A. The Identifiability Test

A recurring analytical thread across the case law is that identifiability is doing most of the doctrinal work. If nobody could reasonably identify the claimant from the defendant’s use, a personality-rights claim is weak; if the defendant reproduces enough distinctive characteristics name, voice, appearance, dialogue, mannerism that the public immediately recognises the individual, the claim strengthens, regardless of whether a single element (a photograph, a name) is copied in isolation. Personality rights are therefore best understood as protecting a bundle of identifiable attributes rather than a single right in a photograph or name, a reading reinforced by the Jackie Shroff litigation’s express reliance on D.M. Entertainment, Titan Industries and Anil Kapoor as a continuous line.

B. Ideas Cannot Become Personality Property

An important counter-limit follows: personality rights should not become a monopoly over ideas. An educator cannot ordinarily claim exclusive ownership of the proposition that education should encourage creativity over rote marks; a scientist cannot own a scientific idea merely because it became publicly associated with them; a social reformer cannot prevent others from discussing their philosophy. Copyright protects particular expression in defined circumstances; personality rights protect aspects of identity. Collapsing the two would dramatically and illegitimately expand the doctrine’s reach, turning it into a general right to control how one’s ideas and public persona are discussed, dramatised or reinterpreted by others.

C. Case Study: Phunsukh Wangdu, Rancho and the Contested Origins of 3 Idiots

The point is well illustrated by the unresolved 2026 controversy over 3 Idiots’s protagonist. For years, Phunsukh Wangdu/‘Rancho’ was popularly associated with Ladakhi innovator and educationist Sonam Wangchuk. In July 2026, however, Aamir Khan publicly denied that Wangchuk inspired the character, while director Rajkumar Hirani and producer Vidhu Vinod Chopra offered differing accounts Hirani pointing to an FTII student as an important inspiration, Chopra connecting the character’s name to a former classmate even as Wangchuk himself had earlier described the film not as his biopic but as merely “inspired” by him.

This factual disagreement is culturally significant but legally secondary. Even if a film character is admitted to have drawn on a real person, the legal inquiry only begins thereafter, and turns on further questions: how much of the real person’s identity was reproduced; whether the person is identifiable from the finished work; whether the persona was commercially appropriated (as opposed to merely referenced); whether the work implies endorsement; whether the treatment is artistic expression rather than promotional use; and whether there is resulting deception or reputational harm. A fictional character can thus occupy a legally intermediate space containing fragments of reality while remaining an independent creative construction and the difference that matters is not fact versus fiction but the use of an idea or philosophy as against the appropriation of an identity for commercial exploitation.

V. Biography, Public Domain and Posthumous Personality Rights

A. Krishna Kishore Singh v. Sarla A. Saraogi Public Domain Facts and Biographical Film

Krishna Kishore Singh v. Sarla A. Saraogi & Ors., Delhi High Court, arising from an attempt by the father of actor Sushant Singh Rajput to restrain release of a film based on events surrounding his son’s death, is a significant limiting authority. The Delhi High Court held that publicly available information may legitimately be used in creating a film, and declined interlocutory relief founded on personality, privacy and publicity rights asserted on the deceased actor’s behalf reasoning that prevents personality rights from becoming an automatic monopoly over facts that have already entered the public domain. The case yields a clean working principle: talking about a person, reporting on them, or dramatising publicly known events concerning them is not the same as commercially exploiting their identity, and biography, journalism and docudrama are not rendered actionable merely because they concern an identifiable, non-consenting individual.

B. The Posthumous Problem

The same case confronted the hardest structural question in this field: who, if anyone, inherits a persona after death? The Court held that the privacy, publicity and personality interests asserted on Sushant Singh Rajput’s behalf were personal to him and did not survive in the manner his father claimed.

Ordinary property survives its owner; personality is different because it is bound up with a particular living individual’s dignity and autonomy, interests that are conceptually harder to transmit by inheritance than a bank account or a trademark. Yet if publicity rights are instead framed purely as an economic asset (as much of the celebrity commercial-value case law in Parts III–IV tends to do), inheritance becomes intuitive and a legal system that answers every survivability question in the estate’s favour risks converting cultural memory itself into private, heritable property: children of a deceased public figure could in principle control every future depiction, block documentaries, or require a historian’s permission before writing about a public life. Indian law, on the authority of Krishna Kishore Singh, has so far resisted that expansive reading, though the Supreme Court has not addressed the question directly.

VI. The 2022–2026 Celebrity Litigation Wave

In Amitabh Bachchan v. Rajat Nagi & Ors., CS(COMM) 819/2022 (Del HC, 25 Nov. 2022), the Court granted India’s first omnibus John Doe order for personality rights (name/image/voice, catchphrases, KBC lottery scam), with blocking directions to DoT and MEITY. In Anil Kapoor v. Simply Life India, 2023 SCC OnLine Del 6914 (Del HC, 20 Sept. 2023), Pratibha M. Singh J. restrained AI/deepfake misuse of the actor’s voice, gestures, nicknames and ‘Jhakaas,’ holding free speech becomes impermissible when it “crosses the line” into commercial exploitation.

In Arijit Singh v. Codible Ventures LLP, 2024 SCC OnLine Bom 2445 (Bom HC, 26 July 2024) India’s first AI voice-cloning ruling the Bombay High Court restrained synthetic recreation of the singer’s voice/vocal style trained on 456 of his songs, expressly invoking Rajagopal’s privacy framework. Further orders extended protection to Jackie Shroff (persona recognised but relief against a meme-edit YouTuber declined)

• Jaikishan Saraf (Jackie Shroff) v. Peppy Store
• Baba Ramdev v. John Doe, Del HC, 24 Feb. 2026 (72-hour takedown, dynamic injunction)
• Global Health Ltd. (Dr Naresh Trehan) v. John Doe, CS(COMM) 6/2025, Del HC, 8 Jan. 2025  extended doctrine to a surgeon defamed by deepfake medical-advice videos
• Jaya Bachchan v. [Ors.], Del HC, 2025 the Court held, prima facie, that her name, likeness, signature, voice, image and other uniquely identifiable aspects of her persona were protectable against unauthorised commercial exploitation, with directions extending to AI, generative AI, machine learning, deepfakes and face morphing, yet pointedly declined to enjoin all uses of her images, including on movie posters a crucial qualification confirming that recognition of a personality right is not a blanket prohibition on all depiction.

The common signature across this wave is procedural: senior IP counsel, same-day ex-parte hearings, omnibus John Doe relief, and coordinated DoT/MEITY/ISP blocking an enforcement infrastructure deployed, on the reported record, almost exclusively for celebrity plaintiffs. The Jaya Bachchan order’s express carve-out for movie-poster use is nonetheless a useful internal check: even within the celebrity-facing track, courts have periodically declined to convert a personality right into a general veto over every image of the plaintiff.

VII. Artificial Intelligence, Deepfakes and Digital Identity

Anil Kapoor and Arijit Singh together yield a working test: (i) validity of the plaintiff’s interest; (ii) identifiability of the AI output; (iii) commercial nexus (trade/traffic, not commentary); and (iv) technological neutrality the mode (deepfake, cloned voice, GIF) does not change the analysis, though virality heightens urgency.

Executive rule-making has supplemented case law: MEITY’s 2026 amendments to the IT (Intermediary Guidelines) Rules, 2021 define “synthetically generated information,” mandate continuous labelling and metadata traceability, and shorten takedown timelines; the Digital Personal Data Protection Act, 2023 treats voice-prints and biometric data as personal data. These instruments are identity-neutral protecting an ordinary citizen’s cloned voice on the same terms as a film star’s making them the most egalitarian development in the field, though efficacy against anonymous or offshore actors remains untested (comparable EU AI Act labelling was circumvented during the 2024 European Parliament elections).

VIII. Can Ordinary Citizens Actually Enforce Personality Rights?

The clearest limiting statement is Toprankers Edtech Solutions v. LPT Edtech, 2026 SCC OnLine Del 1772 (Del HC, 13 Apr. 2026), where a minor CLAT 2026 topper drawn into a coaching-platform dispute obtained relief against defamation and AI-manipulated content, but Gedela J. expressly refused to found it on a general “personality right,” reasoning that otherwise every “aspirant, candidate, student, citizen… who achieves or is declared a top ranker” would claim identical protection an “absurd and incongruous” outcome. Relief issued via defamation, not personality rights, confirming ordinary citizens must generally use different, less developed causes of action.

Non-celebrity deepfake victims fare similarly: in an unreported 2025 Delhi HC matter involving a private academic and activist targeted by a synthetic-content harassment campaign, relief was framed around dignity/reputation/online safety rather than the commercial “publicity” theory used for celebrities illustrating a bifurcation where celebrities get a muscular property remedy and ordinary citizens (especially women) are relegated to defamation, IT Act and criminal-law routes.

The genuinely universal track is the right to be forgotten, under Article 21. [Name Redacted] v. Registrar General, Karnataka HC, 2017 SCC OnLine Kar 424 first recognised it (redacting a name from a matrimonial quashing order); Karthick Theodore v. Registrar General, 2024 SCC OnLine Mad 6529 (Mad HC), SLP dismissed by SC on 24 July 2024 permitted anonymisation of an acquitted person’s identity; and Laksh Vir Singh Yadav v. Union of India, 2026:DHC:4891 (Del HC, 29 May 2026) a 144-page judgment disposing of petitions by acquitted persons, matrimonial litigants and a sexual-offence victim held the right to move beyond a “chapter of life that the law has formally closed”

is part of privacy under Puttaswamy, directing de-indexing/masking of judgments on a proportionality test (nature of proceedings, seriousness, outcome, lapse of time, continuing public interest) while preserving unredacted records and case-law reasoning. This line’s beneficiaries are private litigants with no commercial persona the most egalitarian branch of Indian identity jurisprudence though even it required senior counsel and, in the Delhi batch, petitions pending since 2016.

IX. Personality Rights v. Free Speech, Parody, Open Justice and “Legal Leverage”

D.M. Entertainment’s parody caveat was elaborated in Digital Collectibles Pte Ltd. v. Galactus Funware Technology, CS(COMM) 108/2023 (Del HC, 26 Apr. 2023), where cricketers and NFT platform Rario sued a rival fantasy-sports operator over blockchain “digital player cards.” Bansal J. refused an injunction, holding publicity rights subordinate to Article 19(1)(a) commercial free speech, and that use of public performance data for in-game assets was not passing off celebrity names used for “lampooning, satire, parodies, art, scholarship, music, academics, news” remain protected.

IP scholar Aparajita Lath (Supreme Court Observer, 2025) criticises most John Doe orders as “poorly reasoned” ex-parte grants that sidestep Rajagopal’s public-record exception, describing the field as operating within the “economics of superstars,” where dominant figures shape rules entrenching their own market power and notes the Supreme Court has never yet decided a personality-rights case on a full record; every leading authority remains an interim High Court order.

Open justice is itself constitutional: Swapnil Tripathi v. Supreme Court of India, (2018) 10 SCC 639 held Article 21 (access to justice) and 19(1)(a) (right to know) entitle the public to witness proceedings of constitutional importance, directing live-streaming subject to exclusions for matrimonial/sexual-offence/security matters, citing Naresh Shridhar Mirajkar v. State of Maharashtra, AIR 1967 SC 1 that open trial is the norm. This sits in direct tension with Laksh Vir Singh Yadav’s de-indexing framework; commentators (including respondent Indian Kanoon) argue Article 19(2)’s grounds are exhaustive and privacy should not become a freestanding, unlisted restriction on access to judicial records.

Personality Rights as Narrative Leverage

A further, distinct risk cuts across nearly every case discussed above: enforcement itself can function as leverage independent of ultimate merit. A personality-rights claim can be entirely legitimate while still creating disproportionate bargaining power, because the mere threat of an ex-parte injunction, a takedown notice or a DoT/MEITY blocking direction may cause a publisher, filmmaker, platform or advertiser to remove material long before any court finally decides whether the claim is sustainable particularly given how routinely such relief has issued ex parte, within a single hearing, in the celebrity wave surveyed in Part VI. The danger is not that personality rights are inherently abusive; it is that the procedural speed of enforcement can itself become a mechanism for controlling public narrative about a powerful, well-resourced plaintiff, structurally analogous to the risk Part XIII identifies for an over-expanded right to be forgotten. A mature doctrine should test any request for broad interim relief against a threshold checklist: Is the claimant identifiable? Is the use commercial? Is endorsement implied? Has a genuinely distinctive attribute been appropriated, or merely an idea, philosophy or publicly known fact (Part IV)? Is the material expressive biography, parody, criticism, news, academic work (Part V) rather than promotional? Does it concern a matter of continuing public interest? Is there actual deception or reputational harm? Is the injunction proportionate to that harm? These questions are what prevent a personality right from becoming a general right of censorship over how a public life is discussed, dramatised or reinterpreted.

X. Judicial Speeches and Extra-Judicial Commentary

Former CJI D.Y. Chandrachud, delivering the 14th Justice V.M. Tarkunde Memorial Lecture, ‘Upholding Civil Liberties in the Digital Age: Privacy, Surveillance and Free Speech’, questioned whether demonstrably false speech is protected under Article 19 at all directly relevant to deepfake litigation, where falsity is precisely what removes content from protection. He has since spoken publicly on judicial accountability and, since November 2024, heads a constitutional-studies centre at NLU Delhi. Such speeches signal institutional direction but carry no binding weight, unlike his authored opinions in Puttaswamy and Swapnil Tripathi.

XI. Comparative Jurisprudence: US, UK and EU

United States: Haelan Laboratories v. Topps Chewing Gum, 202 F.2d 866 (2d Cir. 1953) founded a genuine, assignable right of publicity; Zacchini v. Scripps-Howard Broadcasting, 433 U.S. 562 (1977) is the only such case decided by the US Supreme Court; White v. Samsung, 971 F.2d 1395 (9th Cir. 1992) and Waits v. Frito-Lay, 978 F.2d 1093 (9th Cir. 1992) protect against mere evocation of persona. Roughly half the US states codify the right, in principle available to anyone, though litigated mainly by the famous given the burden of proving commercial value.

United Kingdom: no free-standing image right exists. Claimants use passing off Irvine v. Talksport Ltd., [2002] 1 WLR 2355 requires substantial goodwill and likely public deception; Fenty (Rihanna) v. Arcadia (Topshop), [2015] EWCA Civ 3 reaffirmed no “image right” exists, succeeding only on Rihanna’s specific endorsement history arguably the most candidly elitist of the three comparators.

European Union: French and German civil law protect a general right to one’s own image for every individual, though remedies for non-celebrities are narrower than celebrity endorsement damages; the EU AI Act, 2024, Article 50 imposes identity-neutral deepfake-labelling duties the model India’s 2026 IT Rules amendments emulate. Only the EU’s dignitarian tradition and its technology-neutral AI Act offer a genuinely universal template; it is that model, not the celebrity-driven common-law tort, that India’s regulators have chosen to import.

XII. Critical Analysis: Formally Universal, Practically Elitist?

Three asymmetries emerge. Doctrinal: tests like “identifiability” and “commercial value” are calibrated to market-recognised personas, as Toprankers Edtech makes explicit. Procedural/resource: the fast, John Doe, multi-agency-blocking infrastructure has, on the reported record, served celebrities almost exclusively, while ordinary citizens use slower writ, defamation or criminal routes. Yet a genuine counter-trend exists: the right-to-be-forgotten doctrine is explicitly fame-indifferent and has produced binding relief for non-commercial litigants; the 2026 IT Rules and DPDP Act are identity-neutral; and courts (Toprankers Edtech; Lath’s critique) show self-awareness against over-extension.

The fairest characterisation is two parallel regimes: a fast, commercially sophisticated, celebrity-facing “publicity rights” track functioning as an IP-style asset-protection tool despite its privacy-law origins, and a slower, more dignitarian, formally universal “right-to-be-forgotten” track that better serves ordinary citizens but took a decade (2017–2026) to mature and still awaits a definitive Supreme Court ruling on either strand. The idea/identity boundary (Part IV) and the non-survivability of the right after death (Part V) are the doctrine’s own internal guardrails against runaway expansion, just as the parody exception and the “leverage” checklist (Part IX) guard against its use as a censorship or narrative-control tool by the powerful guardrails that matter precisely because the same procedural speed that protects a celebrity’s commercial interest could, unchecked, protect a well-resourced plaintiff’s preferred version of history.

XIII. The Counter-Argument: Risks of Universalising the Right

• Chilling reporting/biography: Rajagopal itself arose from suppressing a convict’s life story; a robust identity-property right available to every individual, unlike defamation, would not require falsity to ground an injunction threat.
• Loss of the parody safety-valve: publicity claims have no settled fair-use doctrine; broader citizen access risks more numerous, poorly reasoned ex-parte orders of the kind Lath criticises, multiplied across millions of potential plaintiffs.
• Toprankers Edtech’s own warning: a maximalist universal right would be unworkable, inviting opportunistic litigation and diverting judicial resources.
• Open justice erosion: unchecked expansion of the right-to-be-forgotten risks letting well-resourced litigants (not only celebrities) scrub legitimately newsworthy judicial history, the risk Swapnil Tripathi’s open-court values and Indian Kanoon’s submissions in Laksh Vir Singh Yadav were designed to flag.

The synthesis Laksh Vir Singh Yadav itself models is not an all-or-nothing choice: fast protection against fraudulent/exploitative AI-driven identity appropriation for anyone; a generous, defined carve-out for satire, parody, journalism and academic work; and a separate proportionality-based dignitarian track for private individuals escaping a concluded, non-newsworthy episode.

XIV. Conclusion and Recommendations

Indian personality-rights law began as an incident of the universal right to privacy in Rajagopal and Puttaswamy but has developed, through two decades of High Court litigation, a doctrine whose vocabulary and enforcement infrastructure are calibrated to commercially valuable, already-famous plaintiffs. Ordinary citizens are not excluded by constitutional text, but are practically disadvantaged in accessing fast, sympathetic relief a limitation Toprankers Edtech itself concedes. Meaningful ordinary-citizen protection has come chiefly through the parallel, more universal right-to-be-forgotten and data-protection tracks.

Recommendations: (1) a considered final-hearing Supreme Court ruling, or comprehensive statute, is overdue to cure the uncertainty created by a doctrine built entirely on interim orders; (2) any statute should adopt a harm-based, identity-neutral standard focused on non-consensual or fraudulent misuse rather than pre-existing market value extending the 2026 IT Rules’ egalitarian model to the underlying civil right; (3) any expansion must preserve express, generous exceptions for satire, parody, journalism, academic work, biography and open judicial reporting, protected so far only inconsistently and largely at the level of obiter caution; (4) the doctrine should codify, as a threshold test before any broad ex-parte relief, the multi-factor checklist identified in Part IX (identifiability, commercial nexus, endorsement, genuine attribute-appropriation as against mere idea or public-domain fact, expressive versus promotional character, public interest, deception, proportionality); and (5) the non-survivability of personality rights after death, as held in Krishna Kishore Singh, should be legislatively confirmed rather than left to case-by-case interlocutory reasoning, so that biography, documentary and historical film-making are not held hostage to estate consent.

This article is researched and co-authored by Mr. Vijay Pratap Singh, a final year student at VIPS, New Delhi

References

Constitution and Statutes

1. Constitution of India, Arts. 14, 19(1)(a), 19(1)(g), 19(2), 21, 145(4).
2. Code of Criminal Procedure, 1973, s. 327.
3. Indian Penal Code, 1860, s. 228A.
4. Information Technology Act, 2000, ss. 66C, 66E, 67, 67A.
5. Information Technology (Intermediary Guidelines) Rules, 2021, as amended in 2026.
6. Digital Personal Data Protection Act, 2023.
7. Trade Marks Act, 1999.
8. Copyright Act, 1957, s. 38B.
9. EU AI Act (Regulation 2024/1689), Art. 50.
10. UK Trade Marks Act, 1994, s. 10.

Indian Judgments

1. Naresh Shridhar Mirajkar v. State of Maharashtra, AIR 1967 SC 1.
2. R. Rajagopal v. State of T.N., (1994) 6 SCC 632.
3. Phoolan Devi v. Shekhar Kapoor, 1994 SCC OnLine Del 722.
4. ICC Development v. Arvee Enterprises, 2003 (26) PTC 245 (Del).
5. D.M. Entertainment v. Baby Gift House, CS(OS) 893/2002 (Del HC 2010).
6. Shivaji Rao Gaikwad v. Varsha Productions, 2015 (62) PTC 351 (Mad).
7. Titan Industries v. Ramkumar Jewellers, 2012 SCC OnLine Del 2382.
8. [Name Redacted] v. Registrar General, Karnataka HC, 2017 SCC OnLine Kar 424.
9. Justice K.S. Puttaswamy v. Union of India, (2017) 10 SCC 1.
10. Swapnil Tripathi v. Supreme Court of India, (2018) 10 SCC 639.
11. Subranshu Rout v. State of Odisha, BLAPL 4592/2020 (Ori HC).
12. Amitabh Bachchan v. Rajat Nagi, CS(COMM) 819/2022 (Del HC).
13. Anil Kapoor v. Simply Life India, 2023 SCC OnLine Del 6914.
14. Digital Collectibles v. Galactus Funware, CS(COMM) 108/2023 (Del HC).
15. Karan Johar v. Indian Pride Advisory, Bom HC 2024.
16. Arijit Singh v. Codible Ventures, 2024 SCC OnLine Bom 2445.
17. Jaikishan Saraf (Jackie Shroff) v. Peppy Store, CS(COMM) 389/2024 (Del HC).
18. Karthick Theodore v. Registrar General, 2024 SCC OnLine Mad 6529 (SLP dismissed, SC, 24 July 2024).
19. Krishna Kishore Singh v. Sarla A. Saraogi, Del HC (citation unverified in this pass).
20. Global Health Ltd. v. John Doe, CS(COMM) 6/2025 (Del HC).
21. Jaya Bachchan v. [Ors.], Del HC, 2025 (citation unverified in this pass).
22. Baba Ramdev v. John Doe, Del HC, 24 Feb. 2026.
23. Toprankers Edtech v. LPT Edtech, 2026 SCC OnLine Del 1772.
24. Laksh Vir Singh Yadav v. Union of India, 2026:DHC:4891 (Del HC).

Foreign Judgments

1. Haelan Laboratories v. Topps Chewing Gum, 202 F.2d 866 (2d Cir. 1953).
2. Zacchini v. Scripps-Howard Broadcasting, 433 U.S. 562 (1977).
3. White v. Samsung Electronics America, 971 F.2d 1395 (9th Cir. 1992).
4. Waits v. Frito-Lay, 978 F.2d 1093 (9th Cir. 1992).
5. Abdul-Jabbar v. General Motors, 85 F.3d 407 (9th Cir. 1996).
6. Irvine v. Talksport Ltd., [2002] 1 WLR 2355.
7. Fenty (Rihanna) v. Arcadia Group (Topshop), [2015] EWCA Civ 3.

Speeches and Select Commentary (Persuasive Only)

1. D.Y. Chandrachud CJI, 14th Justice V.M. Tarkunde Memorial Lecture, “Upholding Civil Liberties in the Digital Age” (reported, Deccan Herald).
2. Aparajita Lath, “Personality rights: The law must not overprotect fame,” Supreme Court Observer (30 Oct. 2025).
3. SCC OnLine Blog, “India’s Evolving Personality Rights Law” (5 Dec. 2025).
4. SCC OnLine Blog, “Right to Be Forgotten Is a Facet of Article 21” (3 June 2026).
5. Freshfields, “India targets deepfakes and AI-generated content.”
6. World Trademark Review, coverage of Delhi HC AI/deepfake orders.
7. WIPO Magazine, “AI voice cloning: how a Bollywood veteran set a legal precedent” (17 Apr. 2025).
8. Cyril Amarchand Mangaldas Dispute Resolution Blog, “The Right To Be Forgotten” (Sept. 2025).
9. Centre for Internet and Society, “Right to be Forgotten: A Tale of Two Judgements.”
10. The Indian Express, 2026 reportage on the Aamir Khan/Rajkumar Hirani/Vidhu Vinod Chopra/Sonam Wangchuk dispute over the inspiration for Phunsukh Wangdu in 3 Idiots.