New Delhi, April 25: The Delhi High Court has granted an ex parte ad-interim injunction protecting the personality rights of Lucknow Super Giants (LSG) owner and industrialist Sanjiv Goenka, barring unauthorised use of his name, image, likeness, and other personal attributes across digital platforms — including content fabricated through artificial intelligence (AI). The order was passed on a commercial suit filed by Goenka against Google LLC and other major intermediaries alleging widespread misuse of his identity through defamatory and misleading content.

Court Finds Prima Facie Strong Case

A single-judge Bench of Justice Tushar Rao Gedela passed the interim order, recording that Goenka had established a "prima facie strong case" and that the balance of convenience clearly favoured him. The court further held that denying interim relief would cause "irreparable injury" to his reputation.

The order described Goenka as a "distinguished and internationally recognized business leader, philanthropist, and visionary entrepreneur" who heads the RP-Sanjiv Goenka Group, a multi-billion dollar conglomerate with diversified business interests spanning multiple sectors.

Nature of Infringing Content

The suit highlighted that numerous social media posts, videos, and AI-generated content were misappropriating Goenka's identity — portraying him in a derogatory manner, spreading misinformation, and causing serious reputational harm. The court reviewed material placed on record and found several posts and video reels to be "downright derogatory", using expletives that were described as "unpalatable in any civil society."

Critically, the court distinguished such content from protected forms of expression. Justice Gedela observed: "The nature of the contents… do not fall within the ambit of mere parody, lampooning or caricature… many of them infringe on the plaintiff's personality rights, particularly those which are generated by AI."

The judge also noted that several posts appeared designed to spread fake information while portraying Goenka in a poor light — going well beyond what free speech protections permit under Indian law.

Scope of the Injunction

In its directions, the Delhi High Court restrained unknown defendants — referred to as John Doe entities — and other parties from using or commercially exploiting Goenka's name, including common variants such as "Sanjeev Goenka" and "S. Goenka", as well as his image, voice, likeness, and other identifiable personal attributes without explicit authorisation.

The injunction specifically covers misuse through emerging technologies including AI, deepfakes, machine learning models, and chatbots — marking one of the most technologically comprehensive personality rights orders issued by an Indian court to date.

Directions to Google, Meta, and X Corp

The court directed major intermediaries — including Google LLC, Meta Platforms Inc., and X Corp. — to immediately take down infringing URLs identified by the plaintiff. The platforms were also ordered to disclose Basic Subscriber Information (BSI) of accounts and channels responsible for uploading such content.

Importantly, upon receiving further details of infringing material from Goenka, the platforms must "immediately block access" to such content — placing a proactive compliance obligation on the tech giants rather than a reactive one.

On the right of publicity, Justice Gedela cited established precedents, stating: "The right of publicity protects against the unauthorised appropriation of an individual's very persona which would result in unearned commercial gain to another."

Legal Background and Broader Implications

This ruling arrives at a pivotal moment for personality rights jurisprudence in India. Indian courts have increasingly grappled with AI-generated impersonation, with earlier landmark cases involving Anil Kapoor and Jackie Shroff establishing foundational precedents for protecting celebrities from deepfake misuse. The Goenka case extends this protection explicitly to the business and corporate leadership community.

Notably, the case also reflects a growing judicial recognition that AI-generated content poses unique threats to individual identity — threats that existing defamation and intellectual property frameworks were not originally designed to address. The court's explicit mention of deepfakes and machine learning in its restraint order signals a judiciary increasingly attuned to the pace of technological change.

The matter has been listed before the Joint Registrar on July 16, 2025 for completion of pleadings, and before the Delhi High Court on September 18, 2025 for further hearing — dates that will be closely watched by legal experts, tech companies, and public figures across India.