In the same week, two different High Courts decided that Kangana Ranaut owns herself. Only one of them was hearing her case.
On 8 October the Delhi High Court granted her a personality rights injunction, holding that her stature “inherently grants her proprietary rights over her personality and associated attributes”. Around 14 October, in Bombay, Justice Sandeep Marne refused an injunction to Phantom Studios against JioStar over the film Queen Forever, and part of his reasoning was that the goodwill generated by a film does not belong to its producer alone. It attaches to the performer too.
She was not a party to the second case. Nobody has connected the two. They are the same idea arriving from opposite directions.
The Bombay case
Phantom Studios India sued JioStar India over Queen Forever, claiming ₹250 crore in damages. Bar and Bench has the account.
Phantom’s case is that Queen Forever breaches a co-production agreement of 2012 and a deed of novation of 2022, and that Phantom and JioStar, formerly Viacom18, are joint and equal owners of the intellectual property and derivative rights in the 2014 film Queen. Trigger Happy Studios and Digital 18 Media also appeared. The interim application was refused and dismissed. The suit itself continues.
The grounds are worth going through, because each one is a trap a producer could fall into.
The title is generic. The Court held that “queen” is “a laudatory and descriptive word for high feminine virtue” and had acquired no secondary meaning pointing to Phantom’s film. A title that is an ordinary English word gets very little protection, however famous the film becomes.
Goodwill is not the producer’s alone. “A film generates goodwill not only for its producer.” The affection audiences have for Queen is substantially affection for a performance, and that does not sit on a producer’s balance sheet.
Delay. Twelve years passed and Phantom made no sequel. Principal photography on Queen Forever was complete. JioStar said Phantom had known about the project since April 2025.
And the line that deserves to be quoted back at every lawyer who argues audience confusion: “It would be too dangerous for the courts to assume that today’s moviegoers are not intellectual enough.”
Counsel on both sides were as heavy as it gets. Senior Advocates Darius Khambatta and Sharan Jagtiani for Phantom, Ravi Kadam for JioStar, Ashish Kamat for Trigger Happy, Birendra Saraf for Digital 18. One procedural note: there was an earlier, separate refusal of urgent ex parte relief to Phantom in this same dispute around July. These are two different orders and should not be conflated.
Why the pairing matters
We have spent this month writing about a new right in a person’s identity being built out of cases where nobody contests anything. Our piece on that is here. Four actors got sweeping orders in a week against deepfake sites and anonymous sellers who filed nothing.
Queen Forever is the control experiment. A plaintiff with a twelve-year paper trail, a ₹250 crore claim and two of the best Senior Advocates in the country lost its interim application, because the defendant was a real company with real counsel and a real argument. Same month, same kind of claim about who owns the value in a piece of work, completely different outcome.
The variable was never the strength of the right. It was whether anyone turned up.
And a problem for producers
Follow the goodwill reasoning to where it goes and it is uncomfortable for the people who finance films.
If the affection an audience has for a film belongs substantially to its performer, then a producer’s claim over the sequel, the remake, the franchise and the derivative is weaker than Indian producers have assumed for decades. The economics of this industry rest on the opposite belief: that you buy the IP, you own the world, and the actor is an input cost.
Put it next to the other thing happening in October. In Delhi, actors are being handed proprietary rights over their own identity, enforceable against platforms and ministries in 72 hours. In Bombay, a producer is being told the goodwill in his own film is not entirely his.
Both of those shift value from the people who put up the money to the people who appear on screen. That is probably the right correction, given how Indian performers have historically been treated. It is also a significant reallocation of leverage that is happening through unrelated interim orders rather than through any kind of considered decision.
Bengaluru Baath Take
The best sentence written by any Indian judge this month was about the audience, not the law. “It would be too dangerous for the courts to assume that today’s moviegoers are not intellectual enough.”
Almost every confusion claim in Indian entertainment litigation rests on the opposite assumption: that viewers are credulous, that a similar title will fool them, that they cannot tell one film from another. The industry makes the same assumption when it commissions its ninth remake and its fourth franchise extension of the year. A judge has now put on the record that the courts should not join in.
Phantom still has a suit running and may well win it on the contract, which is where its real case lives. But the interim stage was lost on a simple point: you cannot sit on a franchise for twelve years, let somebody else finish shooting a film, and then arrive asking a court to treat the delay as somebody else’s problem.
