What Is the Salman Khan Personality Rights Case? The Legal Battle Between Celebrity Identity and AI Platforms
The High Court of Delhi issued a notice on January 21, 2026, to actor Salman Khan on an application filed by a Chinese-based AI voice generation platform seeking to vacate an interim injunction protecting the actor’s personality rights. While the main matter was heard on January 23 by the Joint Registrar (Judicial), the Chinese app’s application is listed for February 27.
This ongoing case has generated significant interest in the legal battle between individual personality rights, particularly in the context of celebrities, and technology companies operating AI-driven platforms in India. The outcome could set important precedents for how personality rights are protected in the age of artificial intelligence.
Who Is John Doe?
The original suit named 28 defendants, including major technology companies such as Apple Inc., Google LLC, Meta’s Facebook and Instagram, X, e-commerce platforms including Amazon India and Flipkart, and intermediaries like Telegram FZ LLC. Mr. Khan also sought an injunction against unknown persons, joined as Defendant No. 1 (John Doe’ or ‘Ashok Kumar’), a procedural device that allows courts to pass ex-parte orders where defendants cannot be identified.
This “John Doe” order is a common tool in intellectual property and personality rights cases. It allows the court to restrain unidentified persons from infringing on rights, recognizing that in the digital age, violations can come from anonymous sources. The order can be enforced against anyone who receives notice of it, even if they were not originally named in the suit.
How Do Personality Rights Operate?
In K.S. Puttaswamy v. Union of India (2017), the Supreme Court recognised privacy as a fundamental right under Article 21. Courts have since held that unauthorised commercial exploitation of an individual’s persona may infringe the right to life. Personality rights recognise the economic value of identity, particularly for public figures, and are distinct from statutory property rights.
In a 2025 order involving Aishwarya Rai Bachchan, the Delhi High Court noted that unauthorised use of a celebrity’s identity could cause commercial harm. Courts have restrained false impersonation, unauthorised use of images and names by websites and AI tools, and the creation of manipulated or inappropriate content.
While Article 19(1)(g) guarantees Indian citizens the right to conduct business, this right is subject to reasonable restrictions. Courts have also protected artistic expression, provided such works do not mislead the public or imply endorsement. Foreign entities, however, cannot invoke Article 19 before Indian courts.
The Chinese App Context
In 2020, the Union government banned over 200 Chinese applications under Section 69A of the Information Technology Act, citing national security concerns related to data collection and storage. Although the Digital Personal Data Protection Act, 2023, has been passed, enforcement remains pending, leaving gaps in regulation, particularly in the AI sector.
Nandan Nilekani recently said voice-based AI is critical for digital equity and could be like a UPI-moment for India. A dismissal of the Chinese platform’s application could have broader implications for misuse by AI companies. If the court allows the Chinese app to continue operating while using celebrity voices without authorisation, it could open the floodgates for similar violations.
The Chinese context adds a geopolitical dimension to the case. With hundreds of Chinese apps already banned in India, the court must consider not only the personality rights of the celebrity but also broader issues of data security and national interest.
Fees in Celebrity Suits
Personality rights claims are typically filed under the Commercial Courts Act, 2015, since celebrities rarely hold conventional IP rights over their identity. This practice has attracted scrutiny, given the high brand valuations often cited in such suits.
Celebrities argue that their name, image, and voice have commercial value, built over years of work and investment. When companies use these attributes without permission or compensation, they are effectively stealing value. The high valuations reflect genuine economic interests, not inflated claims.
Recent scrutiny in the European Union of generative AI systems such as Elon Musk’s Grok highlights similar regulatory concerns. Regulators worldwide are grappling with how to protect individual identity in an age where AI can replicate voices, images, and mannerisms with uncanny accuracy.
The Regulatory Gap
In India, while the IT Rules, 2021, provide takedown mechanisms, the limited effectiveness of grievance redressal systems has pushed public figures to seek relief directly from High Courts. Ensuring protection against digital impersonation from celebrities to citizens remains a pressing concern.
The gap between technology’s capabilities and the law’s reach is growing. AI can now create convincing deepfakes, clone voices, and generate content that appears to come from real people. The legal framework designed for a pre-AI world is struggling to keep up.
Implications for the Future
The Salman Khan case is not just about one actor’s voice. It is about the broader question of who controls identity in the digital age. If AI platforms can freely use celebrity voices without permission, what stops them from using anyone’s voice? The principles established in this case could apply to every citizen.
The case also tests the effectiveness of Indian courts in protecting rights against foreign entities operating across borders. The Chinese app is based outside India, making enforcement challenging. The court’s orders will need to be backed by cooperation from platforms, intermediaries, and international partners.
Conclusion: A Landmark in the Making
The Salman Khan personality rights case has all the elements of a landmark judgment. It pits individual rights against technological innovation, celebrity interests against platform business models, and Indian law against global technology companies.
The court’s decision will shape how personality rights are protected in the AI era. It will determine whether celebrities—and by extension, all individuals—have control over their digital identities. It will set standards for how AI platforms must operate when using real people’s voices and images.
As the case proceeds, it deserves close attention from legal scholars, technology companies, and anyone concerned about privacy and identity in the digital age. The outcome could resonate far beyond Bollywood.
Q&A: Unpacking the Salman Khan Personality Rights Case
Q1: What is the central issue in the Salman Khan case?
A Chinese AI voice generation platform is seeking to vacate an interim injunction that protects Salman Khan’s personality rights. The platform wants to use Khan’s voice without authorisation. The case tests whether personality rights extend to AI-generated content and whether foreign platforms can be restrained from using Indian celebrities’ identities.
Q2: What are “personality rights” under Indian law?
Personality rights recognise the economic value of an individual’s identity, particularly for public figures. Following the 2017 Puttaswamy judgment recognising privacy as a fundamental right, courts have held that unauthorised commercial exploitation of persona may infringe the right to life. These rights are distinct from statutory property rights.
Q3: What is a “John Doe” order in this context?
A “John Doe” or “Ashok Kumar” order is a procedural device allowing courts to pass orders against unidentified persons. The original suit named 28 defendants but also sought protection against unknown persons who might violate personality rights. This allows the court’s orders to be enforced against anyone receiving notice, even if not originally named.
Q4: Why is the Chinese app’s involvement significant?
In 2020, India banned over 200 Chinese apps under Section 69A of the IT Act over national security concerns. The Chinese app’s application to vacate the injunction raises not just personality rights issues but also questions about data security and whether foreign entities should be allowed to operate while potentially misusing Indian citizens’ data and identities.
Q5: What broader implications does this case have?
The case could set precedents for how personality rights are protected in the AI era, when voices and images can be convincingly cloned. It tests whether Indian courts can effectively protect rights against foreign platforms. The principles established could apply not just to celebrities but to all citizens concerned about digital impersonation and identity theft.
