Delhi High Court Directs Social Media Platforms to Remove Content Violating Salman Khan’s Personality Rights

In a significant development underscoring the judiciary’s growing involvement in safeguarding the digital identity and personality rights of public figures, the Delhi High Court on Thursday ordered major social media intermediaries to take down all content that infringes upon the personality rights of Bollywood actor Salman Khan. The order, which requires compliance within three days, applies to all material hosted on these platforms that may be defamatory, unauthorized, or otherwise violative of the actor’s persona and commercial identity.

The directive was issued by Justice Manmeet Pritam Singh Arora while hearing Khan’s petition seeking urgent protection of his personality rights. The actor, through his senior counsel Sandeep Sethi, argued that several online entities and individuals were misusing his name, image, likeness, voice, and persona across various digital platforms. According to the petition, such misuse not only harmed the actor’s reputation but also encroached on his legally recognized rights of publicity and commercial appropriation.

Khan’s counsel contended that the rampant circulation of unauthorized content — including manipulated videos, misleading advertisements, imitation merchandise, and defamatory posts — amounted to a serious violation of his rights. Sethi noted that the speed and scale at which such material spreads online makes immediate intervention essential. The counsel emphasized that digital manipulation tools, particularly the rise of AI-generated content such as deepfakes, have made it increasingly easy to fabricate content featuring celebrities without their consent.

Justice Arora, acknowledging these concerns, referred to an earlier court order dated November 27 that established a procedural precondition for urgent takedown requests. In that earlier ruling, delivered during the hearing of a similar personality rights case filed by actor Ajay Devgan, the High Court held that any individual seeking removal of infringing content must first approach the relevant social media platform directly under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, commonly known as the IT Rules, 2021. Only after the intermediaries fail to take timely action may the aggrieved party seek judicial intervention.

During Thursday’s hearing, the bench reiterated that social media companies must treat Khan’s plaint as a statutory complaint under the IT Rules, 2021. The judge directed platforms impleaded as defendants in the case — marked as defendants 2, 3, 4 and 6 — to comply within three days. Counsels representing these platforms accepted notice and confirmed that the plaint would be processed as a formal grievance under the applicable legal framework. Justice Arora underscored that intermediaries are obligated under the IT Rules to act swiftly when notified of content that violates the law, particularly in cases involving deepfakes, impersonation, or personality right infringement.

The court also addressed concerns extending beyond social media intermediaries. Khan’s legal team argued that several e-commerce platforms were hosting and selling merchandise featuring the actor’s image and branding elements without authorization. Such unauthorized commercial use, they argued, constituted a violation of the actor’s exclusive right to control the commercial exploitation of his persona — a right increasingly recognized under Indian jurisprudence. Justice Arora noted that, while the immediate direction pertained to social media platforms, the court would issue a separate interim restraining order against these additional entities to halt the sale or promotion of merchandise that infringes Khan’s personality rights.

Justice Arora stated, “I will pass the stay order qua others,” indicating her intention to expand the scope of the restraining order to cover non-intermediary entities such as e-commerce marketplaces and online sellers. This reflects the court’s broader view that the protection of personality rights in the digital era requires comprehensive enforcement, not limited solely to traditional social media platforms.

The court’s remarks point to an evolving legal understanding in India regarding personality rights — a doctrine that encompasses a person’s right to control the commercial use of their identity attributes such as name, image, voice, signature, and other recognizable aspects. While Indian statutes do not explicitly codify personality rights, courts have increasingly recognized them under broader principles of privacy, intellectual property, and common law torts such as passing off. High-profile cases involving actors, sportspersons, and other public figures have contributed to the development of this doctrine, particularly in an age where digital exploitation is more prevalent than ever.

The court’s reference to deepfakes is especially significant. With artificial intelligence enabling hyper-realistic audio and video manipulation, celebrities are increasingly at risk of having their likeness used in misleading, defamatory, or commercially exploitative ways. Several Indian courts have recently expressed concern over the potential societal harms posed by deepfakes and have emphasized the necessity of proactive legal tools to counter such misuse. The issuance of a clear procedural step — requiring direct complaints to intermediaries under the IT Rules — reflects the judiciary’s attempt to streamline recourse for victims of such digital violations.

The IT Rules, 2021 impose a range of due diligence obligations on intermediaries, including time-bound content removal upon receiving actual knowledge of unlawful material. Under Rule 3, intermediaries are required to remove or disable access to content within 36 hours of receiving a valid complaint. In cases involving impersonation, explicit imagery, or privacy violations, the Rules mandate even faster action. By directing social media platforms to treat Khan’s plaint as a formal complaint under these Rules, the High Court has reinforced the statutory mechanisms already in place.

Thursday’s hearing signals the judiciary’s growing impatience with platforms that do not respond quickly enough to complaints involving personality rights. With the online ecosystem expanding rapidly and celebrity impersonation becoming easier, courts are increasingly insisting on compliance and accountability. Salman Khan’s petition adds to a growing list of cases where prominent figures have sought judicial protection against misuse of their persona.

The matter is slated to be heard next on May 18, when the High Court is expected to review the platforms’ compliance, consider the broader restraining orders for non-intermediary entities, and possibly deliberate on long-term measures to prevent recurring misuse. The upcoming hearing may also set the stage for more comprehensive guidelines on the enforcement of personality rights in India.

The court’s intervention reflects a broader shift in India’s legal landscape — one that recognizes the need to protect individuals, especially public figures, from digital exploitation and defamation. As technology continues to evolve, so too must the legal frameworks governing privacy, reputation, and digital identity. The Delhi High Court’s latest order marks an important step in that direction.

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