Delhi High Court Grants Amitabh Bachchan Final Decree Against Unauthorised Commercial Use of His Identity

Final order covers apps, merchandise and anonymous operators

The Delhi High Court has permanently restrained several individuals, businesses and unidentified operators from commercially using Amitabh Bachchan's name, image, voice, likeness or other aspects of his persona without his permission, bringing a case filed in 2022 to a final decree.

Justice Purushaindra Kumar Kaurav delivered the judgment on November 5, 2026, in Amitabh Bachchan v. Rajat Nagi & Ors., case number CS(COMM) 819/2022. Four defendants settled with the actor. Four others failed to appear or submit written defences despite receiving court summons. The decree also covers unidentified infringers, described in court proceedings as John Does.

The dispute involved a mobile application called Amitabh Bachchan Video Call, WhatsApp messages promoting a purported Kaun Banega Crorepati lottery, a general knowledge quiz book, T-shirts, posters and internet domain names incorporating the actor's identity. The court found that commercial uses of his name and photographs without consent falsely suggested his endorsement.

Justice Kaurav explained the finding in the judgment:

The impugned uses employ the plaintiff's very name and photographs, for commercial gain and without his consent, and falsely suggest his endorsement.

The final decree replaces the temporary protection granted on November 25, 2022. For the defendants covered by the order, the restrictions now form part of the final disposal of the suit. Bachchan also retains permission to bring fresh proceedings if further unauthorised use gives rise to a new claim.

What the right to publicity protects

The court treated control over the commercial use of a person's identity as a publicity right. In simple terms, the issue is who gets to decide whether a recognisable person's name, face or voice can be used to sell something or suggest that the person supports it.

Relying on the earlier decision in Titan Industries Ltd. v. M/s Ramkumar Jewellers, Justice Kaurav described the principle:

the right to control commercial use of human identity is the right to publicity

Bachchan's claim concerned the commercial value of an identity that buyers and viewers could immediately recognise. A photograph on a product or a familiar name attached to an application can influence a customer's decision by suggesting a connection with the actor.

The court applied the requirements of validity and identifiability discussed in Titan Industries. It found both satisfied because the disputed uses employed Bachchan's actual name and photographs for commercial gain without his consent. Readers therefore did not need to infer his identity from a vague resemblance or an indirect reference.

The suit also sought relief for passing off. That term describes presenting goods or services in a way that leads people to believe they are connected with someone else's reputation or business. Here, the court's concern was the false suggestion that Bachchan had endorsed the products or services.

How his identity appeared across different products

Rajat Nagi developed the Amitabh Bachchan Video Call application. Manoj Publications published a general knowledge quiz book carrying the actor's photograph. Tamatina sold posters bearing his images, while Mahesh Patel registered the domain name amitabhbachchan.in. All four later reached settlements with Bachchan.

Other allegations concerned WhatsApp messages carrying his photograph to promote a purported Kaun Banega Crorepati lottery, sales of T-shirts and wall posters, and registration of amitabhbachchan.com. Domain registrars, the businesses through which internet addresses are registered, were also included in the suit.

The lottery messages and quiz book brought the actor's identity into contexts involving questions, prizes and general knowledge. The application, merchandise and domain names used different routes to reach consumers. Together, these examples explain why the proceedings addressed physical products, internet addresses and messaging platforms within the same case.

The court's finding of falsely suggested endorsement connects these uses. A person encountering a product with Bachchan's photograph or a service carrying his name could understand that presentation as a sign of his approval. The decree places control over such commercial use with the actor, whose express permission the settling defendants agreed to obtain.

Four defendants accepted binding settlement terms

Nagi, Manoj Publications, Tamatina and Patel were defendants 1, 3, 5 and 8. They acknowledged Bachchan's publicity and privacy rights and undertook not to use his name, image, voice, likeness or other aspects of his persona without express permission.

The commitments addressed the products and services at the centre of their disputes. Nagi said he had taken steps to delete the video call application. Manoj Publications said it had discontinued the quiz book. Tamatina said it had stopped selling the posters. Patel said he had deleted amitabhbachchan.in in November 2022 and had earned no money from it.

The undertakings also bind their legal heirs, representatives and business assignees. This extends the agreed obligations to those who inherit or receive the relevant legal or business interests. Bachchan, in return, gave up his claims for damages and other relief against these four defendants.

The court incorporated the compromise into its decree under Order XXIII Rule 3 of the Code of Civil Procedure, commonly called the CPC. This provision allows a court to record a lawful written settlement and resolve the relevant part of a lawsuit on that basis.

Justice Kaurav found that the agreement had been made voluntarily:

The settlement has been agreed upon without fear or coercion, and the parties appear to have entered into it on their own volition.

The court relied on Gurpreet Singh v. Chatur Bhuj Goel when considering the compromise. The settlement could take effect against the defendants who signed it while the claims against the remaining defendants were resolved separately. This allowed the court to conclude the whole suit through two different procedural routes.

Why the court ruled without a full trial

Defendants 2, 4, 6 and 9 did not appear or file written statements after being served with summons. A written statement is a defendant's formal response to the allegations in a civil suit. Their right to submit those responses had been closed on September 25, 2023.

The court decreed the suit against them under Order VIII Rule 10 of the CPC, which addresses a failure to present a required written statement. Citing Asma Lateef v. Shabbir Ahmad, Justice Kaurav said the provision required judicial examination of the claim before judgment.

The judge found no disputed factual issue requiring a trial. The unauthorised uses involved Bachchan's own name and photographs, their commercial purpose was apparent, and the court found that they falsely suggested endorsement. Requiring the actor to present evidence in the defendants' absence would merely repeat the allegations already set out in his claim, the court concluded.

Rule 27 of the Delhi High Court Intellectual Property Rights Division Rules, 2022 also permits summary judgment in such cases. Summary judgment allows a court to resolve a claim without conducting a full trial when the applicable legal requirements are met.

The result was a final decision against the absent defendants alongside a decree recording the agreements with those who settled. Each route ended with binding court relief, although the reasons for granting it differed.

Why the decree includes unnamed infringers

The court extended the final decree to defendant 10, the John Does. This legal description allows proceedings to address people whose identities are unknown when the case is brought. Bachchan's claim described continuing anonymous misuse through websites, applications, posters and messaging services.

Online activity can present a practical identification problem: a consumer may see an application, website or promotional message without knowing the person operating it. The court took account of that problem when extending the decree beyond the named defendants.

The interim injunction issued in 2022 had already covered unknown infringers. The final judgment carries that protection into the decree concluding the suit. It also gives Bachchan liberty to institute fresh proceedings if a new cause of action arises, meaning further conduct creates grounds for another legal claim.

The settlement terms set out specific commitments concerning the application, book, posters and amitabhbachchan.in. No amount of damages awarded against the remaining defendants was specified in the details of the final decision.

From temporary protection to a final decree

Bachchan's case moved through an initial injunction, procedural deadlines, settlement discussions and final judgment. The key dates show how the court's temporary intervention developed into a completed civil suit:

• November 25, 2022: The Delhi High Court granted an interim injunction protecting Bachchan's personality rights, including against unknown infringers.
• September 25, 2023: The right of defendants 2, 4, 6 and 9 to file written statements was closed.
• October 9, 2026: The court directed Bachchan to appear personally if settlement failed and he wished to pursue the case against the defendants concerned.
• November 5, 2026: Justice Kaurav recorded the settlement with four defendants and decreed the suit against the nonappearing defendants and John Does.
• November 16, 2026: A previously scheduled hearing was cancelled after the suit was disposed of.

The October direction came while some parties were exploring settlement. The November 5 judgment resolved the case before that later hearing was needed.

The original interim order was issued by Justice Navin Chawla. At that stage, the court also directed the Ministry of Electronics and Information Technology and telecom service providers to remove flagged content. Those directions addressed the practical task of restricting access to the material identified in the proceedings.

Justice Chawla described the actor's public recognition and advertising presence in the earlier ruling:

It cannot seriously be disputed that the plaintiff is a well-known personality and is also represented in various advertisements

The final decree now absorbs that interim injunction. Temporary protection during the lawsuit has become relief contained in the judgment disposing of it, almost four years after the initial order.

A case spanning physical sales and digital distribution

Bachchan's proceedings brought a publisher, an application developer, a poster seller and a domain registrant into the same legal dispute. That range is central to the outcome: the commercial use of a recognisable identity can occur on a printed cover, through merchandise or within a digital service.

The remedies reflect those different forms of distribution. Discontinuing a book addresses publication; stopping poster sales addresses merchandise; deleting an application or domain addresses particular digital uses. The shared undertaking is broader, requiring permission before using Bachchan's persona commercially again.

Other actors have sought related protection. Aishwarya Rai Bachchan obtained interim relief in 2025 concerning unauthorised uses of her identity across digital platforms and commercial products, including uses involving artificial intelligence. Abhishek Bachchan also obtained interim protection against commercial exploitation of identifiable aspects of his persona. Anil Kapoor secured an interim order covering his name, image, voice and distinctive attributes, including his catchphrase Jhakaas.

Amitabh Bachchan's case has now reached a final decree through settlements with four defendants and judgment against those who did not respond. Its concrete result is a set of permanent restrictions, specific undertakings to discontinue disputed uses and continuing coverage of unidentified infringers.

Key Points

• Justice Purushaindra Kumar Kaurav passed the final decree on November 5, 2026, in CS(COMM) 819/2022.
• The order restrains unauthorised commercial use of Bachchan's name, image, voice, likeness and other aspects of his persona.
• Rajat Nagi, Manoj Publications, Tamatina and Mahesh Patel settled and accepted binding restrictions.
• Four other defendants failed to appear or file written defences, and the court ruled against them without a full trial.
• The decree extends to unidentified infringers operating through websites, applications, posters and messaging platforms.
• The November 2022 interim injunction has merged into the final decree, and Bachchan may bring fresh proceedings over new misuse.