8 9 10 11 12 13 14 15 16 17 18 19 20 21 Is the movie actually a re-enactient of SSR‘s life and 18 – 18.11 history – Value of disclaimer Rights of privacy, publicity and personality 19 19.4 – 19.4.9 R. Rajagopal 19.5 – 19.5.4 Khushwant Singh 19.6 – 19.6.4 Titan Industries 19.7 I.C.C. Development 19.8 – 19.8.7 Deepa Jayakumar The Takeaway 20 Applying the law to the facts 21.1 – 21.5 A few remaining points 22 Celebrity rights 22.1 – 22.1.4 Right to free trial 22.2 Passing off 22.3 23 - 25 Conclusion Facts 1. The plaintiff is the father of Sushant Singh Rajput (―SSR‖, hereinafter), an actor who debuted in Bollywood in 2009 and met an untimely end on 14 June 2020. The circumstances in which SSR breathed his last remain murky, and the dust is still to settle. 2. In or around 19 March 2021, the plaintiff instituted the present suit by way of a quia timet action. The suit was predicated on information stated to have been received by the plaintiff to the effect that Defendants 1 and 2 were in the process of producing, and Defendant 3 in the process of directing, a movie based on the life of SSR, without taking the permission of any of his legal representatives, including the plaintiff. The plaintiff contended that SSR did not leave, behind him, any Class I heir and that the plaintiff was the sole surviving legal heir in Category I of the Class 2 legal heirs of SSR. The suit sought a decree of permanent injunction, restraining the defendants and all others from using SSR‘s name, caricature or Signature Not Verified Signed By:KAMLA CS(COMM) RAWAT Signing Date:12.07.2023 10:10:24 187/2021 Page 2 of 68