Personality Rights vs Free Speech: Madras HC Refuses Takedown of Social Media Posts in T Rangaraj–Joy Crizildaa Case

The Madras High Court has observed that social media content can be directed to be taken down if it amounts to commercial exploitation of a person’s personality rights, while dealing with a high-profile dispute involving celebrity chef and entrepreneur T. Rangaraj and costume designer Joy Crizildaa.

"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 ...The plaintiff (Rangaraj) 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," court said. 

Justice N. Senthilkumar was hearing interim applications filed by Rangaraj in a commercial suit seeking to restrain Joy Crizildaa and unknown persons from publishing or circulating allegedly defamatory material against him across social media platforms, television channels, and digital media. The plaintiff claimed that such content had caused irreparable harm to his reputation, family life, and commercial interests in the hospitality and entertainment sectors.

Rangaraj contended that Joy Crizildaa, who initially approached him in December 2023 as a professional costume designer, later began posting photographs, videos, and interviews falsely portraying them as husband and wife. He alleged that these posts triggered widespread circulation across YouTube channels and television debates, resulting in monetisation by third parties and unlawful commercial gain through the use of his identity. According to him, more than 150 YouTube channels and thousands of social media accounts had republished the content, amounting to a clear violation of his personality rights.

Opposing the plea, Joy Crizildaa asserted that Rangaraj had misrepresented himself as judicially separated from his wife and married her on 24 December 2023 at a temple in Chennai. She claimed that the relationship resulted in multiple pregnancies and abortions and culminated in the birth of a child in October 2025. To support her version, she relied on photographs of the temple ceremony, WhatsApp chats, medical records, and a lease agreement describing the parties as husband and wife. She argued that her posts were a legitimate assertion of her rights and not defamatory.

While examining the rival submissions, court noted that Rangaraj himself had admitted in the plaint that there was an intimate relationship between the parties. It further recorded that the dispute involved serious allegations from both sides, including claims of marriage, cohabitation, and paternity, which could not be conclusively decided at the interim stage.

Significantly, however, court addressed the scope of relief in cases involving alleged misuse of personality rights on digital platforms. Justice Senthilkumar observed that intervention by courts is justified where online content crosses the line from personal assertion into commercial exploitation, particularly when a person’s identity is monetised by third parties through re-telecasts, interviews, or sensationalised content. Court clarified that in such circumstances, takedown directions could be issued to prevent continued commercial gain from disputed material.

At the same time, the judge underscored that prior restraint on speech, especially in defamation-related disputes, must be exercised with caution. Relying on settled principles, court held that interim injunctions restraining publication cannot be granted unless it is clear that the defence of justification would fail at trial. Court also noted that Rangaraj had not produced material to show that he had immediately objected to the posts by issuing legal notices or lodging police complaints at the relevant time.

Court further took note of criminal proceedings initiated against Rangaraj based on Joy Crizildaa’s complaint and the recommendations passed by the Tamil Nadu State Commission for Women, which remained unchallenged. 

Court held that Rangaraj failed to established his case as against Crizildaa and since the balance of convenience and irreparable injury were in favour of Crizildaa, court rejected the interim prayers. 

"In view of the above discussions, both the applications are dismissed. No costs. Post the Suit in the usual course," court ordered. 

Case Title: T.Rangaraj vs. Ms.Joy Crizildaa, John Doe/s

Order Date: January 7, 2026

Bench: Justice N. Senthilkumar