Delhi High Court Questions Need To Retain Social Media Platforms In Karan Johar’s Personality Rights Suit After Takedown Compliance

Delhi High Court Questions Need To Retain Social Media Platforms In Karan Johar’s Personality Rights Suit After Takedown Compliance

Introduction

The Delhi High Court has questioned the necessity of retaining social media intermediaries as parties in a personality rights suit filed by filmmaker Karan Johar after they complied with interim takedown directions. Justice Jyoti Singh observed that there appeared to be a “more the merrier” approach in insisting that platforms remain arrayed as proforma defendants.

Factual Background

Karan Johar had instituted a suit seeking protection of his personality rights against alleged unauthorised and disparaging use of his name, image and persona. By an interim order dated September 17, 2025, the Court had directed removal of specified infringing content and restrained further misuse.

Pursuant to that order, social media platforms including Meta (Defendant 15), X Corp. (Defendant 16) and Etsy (Defendant 12) were impleaded as proforma parties for the limited purpose of compliance with the takedown directions and furnishing relevant details such as IP logs of account holders.

Procedural Background

At the present hearing, Meta submitted that it had fully complied with the interim order and sought deletion from the array of parties. Similar submissions were advanced by other intermediaries, who argued that having complied with court directions, there was no necessity for them to continue as parties in the suit.

Counsel for the plaintiff opposed deletion, contending that the interim order included a John Doe direction and that potential future infringements may require continued presence of intermediaries to ensure compliance.

Issues

1. Whether social media intermediaries who have complied with takedown directions should continue as proforma parties.

2. Whether a John Doe order justifies retaining compliant platforms in the array of parties.

3. Whether deletion of such parties requires a formal application under procedural law.

Contentions of the Parties

The intermediaries argued that they had fully complied with the Court’s interim directions and that there was no legal basis to continue their impleadment. They sought deletion from the suit.

The plaintiff contended that since the order covered present and future infringing material under a John Doe framework, retaining platforms as parties would facilitate prompt compliance in case of fresh violations.

Reasoning and Analysis

Justice Jyoti Singh questioned the legal foundation for insisting that proforma parties remain in the suit after compliance. The Court observed that intermediaries could always be re-impleaded if there were specific instances of non-compliance.

The Bench remarked that deletion of compliant parties does not prejudice the plaintiff’s rights and that procedural law permits deletion of unnecessary parties. The Court indicated that a simple application under Order I Rule 10 of the Code of Civil Procedure would suffice for consideration of deletion.

The Court also noted that earlier interim recognition of the plaintiff’s proprietary interest in his personality attributes did not automatically require indefinite retention of intermediaries once compliance was achieved.

Decision

The Court directed the intermediaries to file formal applications seeking deletion under Order I Rule 10 CPC. The matter is listed before the Joint Registrar on March 9, 2026 and will be taken up next by the Court on May 4, 2026.