On 17 September, the Delhi High Court offered interim relief to filmmaker Karan Johar, marking one of the most closely watched personality rights cases in India’s entertainment sector. The hearing reflected both the novelty and complexity of disputes arising in the digital age, with Justice Manmeet Pritam Singh Arora remarking at the outset that she found it difficult to deconstruct the plaint, given the sheer range of online content Johar sought to restrain.

At the core of Johar’s claim was the right to control the commercial exploitation of his persona — his name, likeness, voice, and reputation. Justice Arora observed that every individual enjoys such a right, and that the law must recognise monetisation of a personality as a protectable interest. The court accordingly restrained the unauthorised sale of merchandise, the operation of certain related accounts, and the use of Johar’s likeness for commercial gain.

Merchandise sellers and digital creators had been circulating mugs, T-shirts, and phone covers emblazoned with Johar’s image and catchphrases. Several platforms also hosted fake profiles impersonating the director, some of which solicited followers and ran promotions for third-party brands. The court directed that such activities be taken down, stressing that reputation and goodwill function like any other intangible asset and cannot be appropriated by strangers without consent.

While the order secured Johar’s core commercial interests, it deliberately stopped short of granting him a sweeping “dynamic injunction” — the kind courts have increasingly used in film piracy cases to block content that “mushrooms” daily. Justice Arora noted the arguments by counsel for the social media companies, Meta, Google and X, that dynamic relief was not warranted where content ranged from genuine parody to critical commentary. The protection was limited, in her words, to cases where the individual’s persona was being monetised by another without authority.

Satire, memes and the line between critique and disparagement

Johar’s legal team had pressed for broader relief that would extend to memes, GIFs, and other digital parodies. They argued that such content — particularly distorted clips circulated on platforms such as GIPHY and Tenor — often crossed the line into vulgarity and reputational harm. Some GIFs paired scenes from Johar’s films with obscene captions, while others altered his image in ways his lawyers said amounted to character assassination.The court, however, distinguished between disparagement and satire. Justice Arora emphasised that not every parody could be equated with defamation or misappropriation, and that issuing a blanket prohibition would be disproportionate. Instead, the court directed Johar to furnish a more specific list of offending content, indicating it was prepared to examine individual instances rather than suppress entire categories.

Some memes that were considered clearly abusive and disparaging were noted and included in the takedown order, a detailed copy of which will be availalbe shortly.

The line-drawing exercise highlighted the broader difficulty of separating cultural critique from reputational injury in India’s celebrity-driven media space. Defence counsel for intermediaries argued that platforms face an impossible task if asked to act as arbiters of humour. They cited the ongoing debate about nepotism in Bollywood — an issue deeply associated with Johar — as a legitimate subject of commentary, even if personally unflattering.

The court’s refusal to enjoin satire outright aligns with a growing judicial consensus that reasonable humour is protected expression, even where directed at public figures. But it leaves unresolved the question of how to establish objective standards for platforms to follow when determining what crosses into actionable disparagement.

Chandrima Mitra, partner at DSK Legal in Mumbai, said: “Only the person at the centre of satire can determine whether it is harmless or harmful. That makes it very difficult for courts and platforms to enforce consistently.”

Senior Advocate Rajshekhar Rao and Nizzamuddin Pasha, and a team from DSK Legal led by Parag Khandhar, Chandrima Mitra and Krishan Kumar.

Platforms, deepfakes and the burden of enforcement

AI-generated likenesses and voice cloning were also discussed during arguments. Counsel for the social media companies acknowledged that deepfake technologies pose new risks to reputation, but noted that India lacks a clear statutory framework to address them. Without sharper legal guidelines, courts can only extend existing personality rights doctrines to novel situations, case by case, they argued.

For intermediaries such as YouTube, Meta, GIPHY, and Tenor, the order signals a tightening compliance environment but stops short of imposing proactive duties. Some platforms had already taken down content voluntarily after Johar’s suit was filed, indicating that reputational disputes may increasingly be resolved through pre-emptive removal rather than protracted litigation.

Still, the practical challenges of enforcement remain. Anonymous creators — “John Does” or “Ashok Kumars” in Indian legal parlance — can rapidly produce and disseminate fresh content. While courts have used dynamic injunctions to address film piracy, applying the same approach to memes or satire risks collateral suppression of lawful speech. For now, the burden falls heavily on the rights-holder to monitor, report, and pursue takedowns, a costly and time-consuming exercise.

As Mitra added, “There is enough under intermediary obligations for platforms to act proactively, but enforcement is still tedious for rights-holders. John Doe injunctions are a starting point, yet the practical burden of tracking infringers falls on the celebrity.”

Legal framework lagging behind digital reality

The case also underscores how Indian courts are being forced to adapt personality rights doctrine to an era of generative AI and manipulated content. Johar’s plaint flagged AI tools offering “voice swaps” and “custom AI voices” in his name, warning they expose him to humiliation.

According to Mitra, the law is struggling to keep pace. “The present framework doesn’t have clear pointed guidelines of how to deal with these unauthorised content and misuse, hence the increase of litigations in the last few years in this space,” she said.

Without statutory clarity, courts have leaned on constitutional principles of dignity (Article 21) and existing copyright and trade mark law. But as AI proliferates, questions about unauthorised likeness and voice cloning are becoming harder to resolve.

Johar’s interim win confirms that India’s courts will act against commercial exploitation and disparagement of celebrity identity. But the refusal to impose a blanket bar on memes highlights the judiciary’s recognition that digital culture thrives on parody and critique.

The case also raises questions about the obligations of intermediaries such as YouTube, Meta, X, GIPHY, and Tenor. Some defendants, served with Johar’s plaint, voluntarily removed infringing content even before the order.

“There is enough under intermediary obligations where they should proactively take action,” Mitra said. “In some cases they do, like when this suit was filed, some defendants took down the unauthorised material as on the first day of hearing without waiting for an order from court.”

But the practical challenge remains: without bright-line rules, platforms risk either over-censoring satire or leaving defamatory content unchecked.