The Bombay High Court on Wednesday upheld an earlier order restraining the release of a film tentatively titled ‘Shaadi Ke Director Karan Aur Johar’ or ‘Shaadi Ke Director Karan Johar’, ruling that the title infringes upon filmmaker Karan Johar’s personality and publicity rights.
A division bench of Chief Justice Alok Aradhe and Justice M.S. Karnik dismissed an appeal filed by the film’s maker, Sanjay Singh, against a March 2024 order of a single bench that had stayed the release of the film following a plea by Johar.
The court observed that Karan Johar enjoys immense goodwill and reputation in the entertainment industry, both in India and internationally. “The name ‘Karan Johar’ has become a brand name and is inextricably linked with respondent No. 1 (Johar),” the bench stated.
Rejecting Singh’s argument that the addition of the word “aur” between ‘Karan’ and ‘Johar’ would remove any association with the celebrity, the court held that such a combination was still misleading. “The use of the two names in any form is sufficient to create confusion in the public’s mind,” the order noted.
The court further emphasized that Johar, as a celebrity, is entitled to the protection of his personality and publicity rights. “Courts in India have repeatedly recognized the enforceability of such rights, and the respondent is entitled to claim protection against unauthorized commercial exploitation by third parties,” the bench stated.
Highlighting Johar’s brand value, the court concluded that allowing the use of his name in the film title would amount to exploitation of his reputation and goodwill. “The appellant cannot be permitted to ride on the fame of the respondent in this manner,” it added.
