The Madras High Court recently held that a celebrity’s personality rights cannot be used to secure a blanket gag order at the interim stage, especially without prima facie material showing commercial exploitation. (T Rangaraj v. Joy Crizildaa.)
Justice N Senthilkumar dismissed applications filed by celebrity chef and entrepreneur T Rangaraj seeking to restrain costume designer Joy Crizildaa and others from publishing and circulating posts, interviews, photographs and videos about their relationship.
"Merely furnishing the links and photographs will not be sufficient for the court to prima facie come to the conclusion that there is a violation of personality rights of the applicant/plaintiff and in the absence of any specific allegation made with regard to commercial gain to the defendants, the claim made by the applicant/plaintiff seeking an injunction is against the settled principles on the fundamental rights guaranteed under Article 19(1)(a)."
The case was initiated by Rangaraj, a director of Madhampatty Thangavelu Hospitality Private Limited - a company incorporated in 2010 that operates the "MADHAMPATTY PAKASHALA" brand. Rangaraj filed the suit seeking to protect his "personality rights" and reputation from what he alleged were false and malicious communications by Crizildaa.
The legal action was triggered by a series of Instagram posts and interviews published by Crizildaa between July and August 2025. Rangaraj alleged that these publications falsely portrayed a marital relationship and disparaged his personal and professional character. He contended that these statements caused "irreparable commercial loss" and damaged the goodwill associated with his brand. He thus sought both a permanent gag order and a mandatory injunction for the removal of specific social media content.
What the Court held
1. No blanket gag orders: Emphasising constitutional free speech protections, the Court held that “there cannot be a blanket order to restrict or refrain the rights of the individual to express their views,” even where personality rights are invoked.
2. Personality/publicity rights hinge on commercial exploitation: The Court reiterated that publicity rights are limited in scope, noting that “the right to control commercial use of human identity is the right to publicity.” It clarified that personality rights are not triggered merely because personal material circulates online.
3. Genuineness of social media content to be determined at trial:
Observing that the factuality of the material was contested, the Court held that “the genuineness of all these photos, videos etc., are to be determined only by letting in evidence and these are all matter for trial...plaintiff cannot abridge the evidentiary value of the said materials… by seeking an injunction.”
In strong terms, the Court found that “the plaintiff is only making an attempt to shut the voice of the individuals or the social media who are airing their views which are against him,” and rejected the claim on that basis.
The Court ultimately held that Rangaraj has not prima facie established his case and that the balance of convenience and irreparable injury are in favour of Crizildaa, leading to dismissal of both interim applications.
The Court's refusal to grant interim relief was heavily influenced by the nature of the relationship admitted in the pleadings. While Rangaraj sought to restrain speech related to their interactions, the Court noted that he had admitted to a relationship while simultaneously seeking to suppress the defendant's narrative of it.
Furthermore, Crizildaa provided prima facie evidence - including WhatsApp chats and photographs - that indicated a level of intimacy, leading the Court to conclude that the veracity of the allegations required a full trial and could not be suppressed at the interlocutory stage.
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