Delhi High Court Orders Takedown of Unauthorised Use of Bhuvan Bam’s Images, Defers Ruling on Personality Rights

Delhi High Court Orders Takedown of Unauthorised Use of Bhuvan Bam’s Images, Defers Ruling on Personality Rights

Introduction

The Delhi High Court has passed a John Doe order directing the removal of unauthorised images of YouTuber and actor Bhuvan Bam being used online without his consent. While granting immediate protective relief against misuse of images, the Court declined to render a prima facie finding on the existence or scope of the plaintiff’s personality rights at the threshold stage of the proceedings.

Factual Background

Bhuvan Bam, a well-known digital content creator and actor, approached the Delhi High Court alleging unauthorised use of his photographs and images by various unknown individuals and entities across online platforms. The suit complained that such usage was without consent and amounted to misuse of his identity and commercial exploitation of his persona. The plaintiff sought wide-ranging reliefs, including protection of his personality rights, injunctions against unauthorised use of his name and image, and takedown of infringing content.

Procedural Background

The matter came up before Justice Jyoti Singh on the first date of hearing. The Court considered the plaintiff’s application for interim relief and the prayer for issuance of a John Doe order against unknown infringers. Summons were issued in the suit and notice was issued on the interim application.

Issues

1. Whether interim protection could be granted against unauthorised use of the plaintiff’s images.

2. Whether a prima facie finding on the existence and infringement of personality rights could be returned at the very outset of the proceedings.

Reasoning and Analysis

Justice Jyoti Singh drew a clear distinction between granting protective relief against unauthorised use of images and recording a judicial finding on personality rights at the initial stage. The Court observed that while misuse of images could be assessed prima facie on the material placed before it, a declaration or finding on personality rights involved deeper legal examination and could not be conclusively addressed on the first day.

The Court remarked that it would be inappropriate to render a finding on personality rights without pleadings being completed and without hearing the defendants. However, where unauthorised use of images was evident, interim protection could be granted to prevent further misuse.

The judge clarified that protection at this stage would be limited to directing takedown of infringing links and content, without expressing any final or prima facie opinion on the plaintiff’s personality rights.

Decision

The Delhi High Court issued a John Doe order directing removal and takedown of unauthorised images of Bhuvan Bam circulating online. At the same time, the Court expressly declined to give a prima facie finding on personality rights at the threshold stage. The matter has been listed for further hearing on February 4, 2026 and the Court indicated that local commissioners would also be appointed, with detailed directions to follow in the uploaded order.