Bollywood actors Shah Rukh Khan, Ajay Devgn and Tiger Shroff have come under regulatory scrutiny in India after the Maharashtra Food and Drug Administration (FDA) issued show-cause notices over their appearance in an advertisement for Vimal Elaichi. The regulator is investigating whether the campaign amounts to surrogate advertising for Vimal Pan Masala, a product subject to restrictions in Maharashtra.
The advertisement, released in 2024, features the three actors promoting Vimal Elaichi, a cardamom-based mouth freshener associated with the Vimal brand. The FDA has questioned whether the use of the Vimal name, presentation and advertising style indirectly promotes the brand’s pan masala products. The notices reportedly ask the actors to explain their involvement in the campaign and provide details concerning their endorsement arrangements. They have been given 15 days to respond.
The controversy centres on the concept of surrogate advertising. In India, direct advertising of tobacco products is prohibited under the Cigarettes and Other Tobacco Products Act, 2003 (COTPA). Surrogate advertising refers to promotional activity in which a company uses a different product carrying the same or closely associated brand identity to maintain awareness of a restricted product. The distinction between a legitimate brand extension and indirect promotion can, however, depend on the circumstances of a particular campaign.
The Vimal brand has previously faced questions over the use of its name for products such as elaichi while also being associated with pan masala and tobacco-related products. In a 2024 case, the Delhi High Court considered a dispute concerning advertising of Vimal Elaichi and whether the use of the Vimal name could constitute indirect or surrogate promotion. The court noted that determining whether such advertising amounts to surrogate advertising requires consideration of evidence concerning the products and their marketing.
The latest Maharashtra FDA action comes as the state has intensified enforcement against prohibited tobacco and pan masala products. Maharashtra has maintained restrictions on products containing tobacco and nicotine, and authorities have been conducting inspections and seizures as part of the enforcement campaign. The FDA has also indicated that its scrutiny extends beyond the sale of restricted products to advertising and promotional practices connected with them.
The involvement of major Bollywood celebrities has brought additional attention to the issue. Shah Rukh Khan, Ajay Devgn and Tiger Shroff have large public profiles, making their participation in brand campaigns particularly significant from an advertising perspective. The notices do not mean that the actors have been found guilty of violating the law. They are being asked to explain their role before the authorities determine whether further action is warranted.
Celebrity endorsements of pan masala and related products have previously generated controversy in India. Actor Akshay Kumar, who had appeared alongside Ajay Devgn and Shah Rukh Khan in a Vimal campaign, announced in 2022 that he would withdraw from his association with the brand after facing criticism over the endorsement.
The current case therefore raises a broader regulatory question about where legitimate advertising ends and surrogate promotion begins. A company may advertise a legal product such as elaichi, but regulators can still examine whether the campaign’s branding, presentation and market context effectively promote a restricted product.
For the three actors, the immediate issue is their response to the Maharashtra FDA notices. For India’s advertising industry, the case highlights the increasing scrutiny surrounding celebrity endorsements and brand extensions connected to products whose direct advertising is restricted. The outcome could also provide further clarity on how regulators distinguish between advertising a legal product and indirectly promoting a restricted one.
