Delhi HC grants injunction in favour of LSG owner Sanjiv Goenka in personality rights case

New Delhi, April 25 The Delhi High Court has granted an ex parte ad-interim injunction in favour of Lucknow Super Giants (LSG) owner and industrialist Sanjiv Goenka, restraining unauthorised use of his name, image and other personality attributes across digital platforms, including content generated using artificial intelligence (AI).

A single-judge Bench of Justice Tushar Rao Gedela passed the interim order while hearing a commercial suit filed by Goenka against Google LLC and other intermediaries, alleging large-scale misuse of his persona through defamatory and misleading content on social media platforms.

In its order, the Delhi High Court observed that Goenka had made out a “prima facie strong case” and held the balance of convenience lay in his favour, adding that failure to grant interim relief could cause “irreparable injury” to his reputation. It further recorded that the plaintiff is a “distinguished and internationally recognized business leader, philanthropist, and a visionary entrepreneur” who heads the RP-Sanjiv Goenka Group, a multi-billion dollar conglomerate with diversified business interests.

The suit alleged that various social media posts, videos and AI-generated content were misusing Goenka’s identity, portraying him in a derogatory manner, spreading fake news and causing reputational harm. Referring to the material placed on record, the Delhi High Court said that several posts and video reels were “downright derogatory and use expletives, which are unpalatable in any civil society”, and went beyond permissible parody. “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 order said.

Justice Gedela also observed that several posts and video reels placed on record were “distasteful” and portrayed the plaintiff in a poor light, while also appearing to spread fake information. Referring to several precedents, the judge said, “The right of publicity protects against the unauthorised appropriation of an individual's very persona which would result in unearned commercial gain to another.”

In its directions, the Delhi High Court restrained unknown defendants (John Doe entities) and others from using or exploiting Goenka’s name — including variants such as “Sanjeev Goenka” and “S. Goenka” — as well as his image, likeness and other identifiable attributes without authorisation, including through technologies such as AI, deepfakes, machine learning and chatbots.

It also directed intermediaries, including Google, Meta Platforms Inc. and X Corp., to take down infringing URLs identified by the plaintiff and disclose Basic Subscriber Information (BSI) of the accounts and channels responsible for uploading such content. It added that upon receiving further details of infringing content from the plaintiff, the platforms must “immediately block access” to such material.

Justice Gedela has listed the matter before the Joint Registrar on July 16 for completion of pleadings and before the Delhi High Court on September 18 for further hearing.

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