A Celebrity’s Name is Not Public Property – No One Can Exploit It Without Consent – High Court Bars Release of Film Titled ‘Shaadi Ke Director Karan Aur Johar’

Unauthorized Use of a Celebrity’s Name is a Violation of Personality Rights – Bombay High Court Stops Film Misusing Karan Johar’s Name. The Bombay High Court has ruled in favor of filmmaker Karan Johar, restraining India Pride Advisory Private Ltd. and others from using his name in their upcoming film “Shaadi Ke Director Karan Aur Johar.” The court held that a celebrity’s name carries commercial and reputational value, and its unauthorized use for financial gain is a violation of personality rights, publicity rights, and the right to privacy.

Justice R.I. Chagla, while deciding the suit, emphasized, “The Plaintiff’s name is synonymous with a particular style of filmmaking. The use of ‘Karan’ and ‘Johar’ in the title, particularly in the context of Bollywood, is an unmistakable attempt to mislead audiences into believing that the Plaintiff is associated with the film. The Defendants have no right to ride upon the goodwill and reputation of the Plaintiff.”

Rejecting arguments that the film’s title merely referred to two separate characters, the court held that adding a conjunction like "Aur" does not prevent consumer confusion, nor does it absolve the Defendants from liability. The ruling makes it clear that personality rights are legally enforceable and that no one can commercially exploit a celebrity’s identity without consent.

"A Celebrity Has the Right to Control the Commercial Use of Their Name" – High Court Defends Personality Rights

The case stemmed from Karan Johar’s legal action against the filmmakers for deliberately using his name in the movie title, trailers, and promotional material to mislead the public. His counsel argued that his name has become a brand in itself and that its unauthorized usage is a direct infringement of his legal rights.

The High Court upheld this argument, ruling that a celebrity’s identity is a valuable asset that cannot be exploited for commercial gain without permission. Justice Chagla, in his observations, stated, “A celebrity’s name is not merely an identifier; it carries economic significance. The unauthorized use of that name for commercial exploitation amounts to an infringement of personality rights.”

The court further held that such violations are not limited to using an exact name but extend to any deceptive or misleading references that create an impression of association.

"A Mere Disclaimer Cannot Undo the Damage" – Court Rejects Defendants’ Attempt to Justify the Title

The Defendants argued that they were willing to add a disclaimer stating that the film had no connection with Karan Johar. The High Court dismissed this suggestion, ruling that a disclaimer does not mitigate the harm caused by wrongful association.

Justice Chagla observed, “Once an audience is misled, the damage is already done. A disclaimer does not erase the deceptive impact of the title. The public perception of the Plaintiff’s association with the film will continue to exist, even if a disclaimer is added.”

The Defendants also attempted to justify their actions by claiming that the Central Board of Film Certification (CBFC) had cleared the film’s title. The court rejected this argument outright, stating, “The CBFC’s approval does not grant immunity from legal action. Certification by itself does not validate a violation of an individual’s personality rights.”

"The Film’s Content is Inconsistent with the Plaintiff’s Brand – Reputation Must Be Protected"

The High Court took note of the fact that Karan Johar is widely recognized for family-friendly films, while the impugned movie had an ‘A’ certification for adult content. The court found that associating Johar’s name with a film of this nature could cause irreparable harm to his reputation.

Justice Chagla ruled, “A filmmaker’s reputation is built over years of work. Associating a family-friendly filmmaker with an adult-themed film could damage his credibility in the industry. The Defendants cannot exploit the Plaintiff’s goodwill while promoting content that is inconsistent with his brand.”

"A Landmark Judgment on Personality Rights in India" – High Court Grants Injunction Against the Film’s Release

Concluding that the unauthorized use of Karan Johar’s name was unlawful, deceptive, and commercially exploitative, the court issued a permanent injunction against the film’s release under the impugned title.

Justice Chagla ruled, “The Defendants are restrained from using the name ‘Karan Johar’ in any manner whatsoever in connection with the film, including in the title, script, promotions, or advertisements. The film cannot be released with the impugned title, and all promotional materials using the name must be taken down immediately.”

With this judgment, the Bombay High Court has once again reinforced the importance of personality rights and ensured that celebrities are not forced to tolerate the misuse of their identities for unauthorized commercial gain.

Date of decision: 07/03/2025