Public Figures Must Be Thick-Skinned Towards Satirical Criticism: Delhi High Court Refuses To Block AI-Generated Content Against MP Raghav Chadha

"Those who fill a public position must not be too thin-skinned in reference to comments made upon them," Delhi High Court, in a significant ruling, has held that public figures and politicians must accept satirical criticism and public scrutiny as an inevitable part of their profession.

A Single Judge Bench of Justice Subramonium Prasad observed that while the use of Artificial Intelligence to harm an individual's dignity is not endorsed, a fair balance must be struck between the right to reputation and the fundamental right to freedom of speech and expression. The Court noted that those holding public office must not be "thin-skinned" regarding comments made about their political decisions.

The matter arose from a suit filed by Rajya Sabha Member of Parliament Raghav Chadha against unknown defendants and social media intermediaries. The Plaintiff sought a permanent injunction against the unauthorized use of his likeness and the dissemination of AI-generated deepfakes and morphed videos. He alleged that malicious campaigns were orchestrated against him following his political defection from the Aam Aadmi Party to the Bharatiya Janata Party.

The primary question before the Court was whether the AI-generated content targeting the Plaintiff constituted an actionable infringement of personality rights or defamation warranting a pre-trial injunction. The Court was also called upon to determine the threshold for granting interim relief in defamation suits involving public figures and the regulatory duty of the judiciary regarding unregulated AI content.

Plaintiff Abandons Claim Over Personality Rights

At the outset, the Court observed that the suit did not technically pertain to the protection of personality rights as traditionally understood. During the proceedings, the Senior Counsel for the Plaintiff clarified that they would not be pressing arguments regarding personality rights and would instead confine the seeking of reliefs to the issue of defamation. Consequently, the Court disregarded prayers related to the commercial exploitation of the Plaintiff’s persona and focused solely on whether a prima facie case of defamation was established.

The Primacy of the Bonnard Principle in Libel Cases

The Court placed heavy reliance on the landmark English case of Bonnard v. Perryman, which established that an interlocutory injunction to restrain a libel should not be granted unless the alleged statement is proven untrue. This principle suggests that until the falsity of the libel is established at trial, no right is deemed infringed. The Court noted that a mere assertion by a defendant of an intention to justify the allegations is often sufficient to caution a court against granting a pre-trial injunction.

High Threshold for Injunctions Against Public Debate

The Bench referred to the Supreme Court's decision in Bloomberg Television Production Services India Private Limited & Ors. v. Zee Entertainment Enterprises Limited. It reiterated that ex-parte injunctions against publications should only be granted in exceptional cases where the content is "malicious" or "palpably false." The Court emphasized that granting such reliefs in a cavalier manner results in the stifling of public debate and interferes with the public's right to know.

Public Figures Must Tolerate Searching Criticism

While discussing the status of the Plaintiff as a public man, the Court cited various international and Indian precedents, including Seymour v. Butterworth and Kartar Singh v. State of Punjab. The Court observed that those who fill public positions render themselves open to attack and must accept it as a necessary, though unpleasant, appendage to their office. The bench noted that public interest requires that a man's public conduct be open to the most searching criticism, even if such observations are undeserved or unjust.

Dignity vs. Freedom of Expression

The Court referenced Amish Devgan v. Union of India and Subramanian Swamy v. Union of India to acknowledge that while dignity is a quintessential quality of personality under Article 21, the right to speech and expression remains sacrosanct for the progress of democracy. It noted that the standard for defamation for a public figure is comparatively higher, requiring a clear showing of per se defamatory content rather than mere annoyance or inaccuracy.

AI as a Tool for Political Opinion

Regarding the use of technology, the Court acknowledged that Artificial Intelligence has become a contemporary instrument for voicing opinions across social media platforms, particularly in political contexts. It noted that until such content is regulated by stringent legislation, the judiciary must examine whether AI use reaches the threshold of infringing fundamental rights. The Court clarified that it does not endorse the use of AI to produce deepfakes that harm individual dignity, but it must balance this against constitutional freedoms.

Distinction Between Satire and Vulgarity

Upon perusing fifty-two documents annexed to the plaint, the Court found that the majority appeared to be satirical expressions of the Plaintiff's political decisions. It held that humor regarding party alliances, governance, and policies is "part and parcel of politics" and does not automatically constitute defamation. However, the Court identified six specific documents that contained explicit, profane, and vulgar content falling outside the purview of harmless satire.

Final Directions and Conclusion

The Court concluded that the balance of convenience lay in restraining the publication of only those materials that were found to be profane or vulgar. It directed Meta Platforms and other intermediaries to take down the URLs associated with six specific documents within two weeks. Furthermore, the intermediaries were directed to provide the Plaintiff with Basic Subscriber Information and IP logs of the accounts associated with that specific content to help unmask the identity of the anonymous uploaders.

Date of Decision: July 01, 2026