category of intellectual property right. Celebrity rights, he submits, are rights which enure in favour of one by virtue of her, or his, being a celebrity. A celebrity, therefore, according to him, enjoys a distinct bundle of personality rights, privacy rights and publicity rights. As a celebrity, he submits that the personality of SSR could not have been misappropriated for the unjust enrichment of others. 15.2 Mr. Varun Singh submits that the film has been made on the basis of defamatory statements and news articles, which alleged that SSR was subject to various vices such as drug addiction, etc, without any verification and without obtaining any report from any official agency to the said effect. Additionally, the firm alleges that SSR was mentally unwell, that he was anxious and depressed and that he died by committing suicide. In so doing, he submits that the defendants have violated the right to privacy of both of SSR and the plaintiff, which inhere in them by virtue of Article 21 of the Constitution. Mr. Singh submits that it is not permissible for anyone to publish anything about SSR, laudatory or critical, without the plaintiff‘s consent. The impugned film, he submits, is no less than a direct retelling of SSR‘s life. He has drawn attention to various documents, placed by him on record, which underscore this position. A news item dated 19 February 2021, on the virtual platform ―Bollywood Hungama News Network‖ reports the statement of Zuber K Khan, who essays the role of SSR in the impugned movie, to the effect that the film focuses on the lives of Rhea Chakraborty and SSR and the chemistry between them, and was aimed at securing justice not only for SSR but also for Rhea Chakraborty. An item on the ―News 18 Movies‖ platform, Signature Not Verified Signed By:KAMLA CS(COMM) RAWAT Signing Date:12.07.2023 10:10:24 187/2021 Page 15 of 68

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