Vimal Elaichi Ad: 3 Bollywood Stars Get FDA Notices

Bollywood stars Shah Rukh Khan, Ajay Devgn and Tiger Shroff have come under scrutiny from the Maharashtra Food and Drug Administration (FDA) over their participation in a Vimal Elaichi advertisement. The regulator has issued show-cause notices to the three actors, alleging that the campaign may indirectly promote Vimal Pan Masala, a product currently prohibited in Maharashtra.

The notices represent a significant escalation in Maharashtra’s wider crackdown on prohibited tobacco and nicotine-containing products and the advertising practices used to promote brands associated with them. The FDA has asked the actors to explain their roles in the campaign and why legal action should not be initiated against them.

The action is particularly notable because the regulator says it is examining the advertisement as a possible case of surrogate advertising. In such campaigns, a brand associated with a restricted product is promoted through another product or category, potentially allowing the brand name and identity to remain visible to consumers even when direct advertising of the prohibited product is restricted.

Why Shah Rukh Khan, Ajay Devgn and Tiger Shroff received notices

The Maharashtra FDA’s notices concern the actors’ participation as brand endorsers in the Vimal Elaichi advertisement. According to the regulator, the presentation of the advertisement, its dialogue, the product branding and the wider market context raise questions about whether the campaign indirectly promotes Vimal Pan Masala.

The FDA has not, through the show-cause notices, established that the three actors are legally liable. A show-cause notice is an opportunity for the recipients to explain their position before the regulator decides whether further action is warranted.

The actors have been asked to submit written explanations within 15 days. The FDA is also seeking documents connected with the campaign, including endorsement agreements, campaign briefs, remuneration details and evidence of the due diligence undertaken before the advertisement was released.

The request for these records indicates that the regulator is examining not only what appeared in the advertisement but also the circumstances surrounding the celebrities’ participation.

What is surrogate advertising?

Surrogate advertising becomes relevant when a company promotes a product that is legally marketable while using branding, imagery or other elements closely associated with a restricted product.

The practice has long been controversial in India, particularly in sectors involving tobacco, alcohol and other products subject to advertising restrictions. A familiar strategy has been to promote an ostensibly different product under the same or a closely related brand identity.

In the Vimal case, the Maharashtra FDA’s concern is that the Vimal brand has a strong association with pan masala. The regulator is therefore examining whether advertising Vimal Elaichi nevertheless creates promotional value for the prohibited pan masala product.

This distinction is at the centre of the latest notices. The question is not simply whether elaichi, or cardamom, can legally be marketed as a food or mouth-freshener product. The regulatory issue is whether the particular campaign indirectly promotes a prohibited product through its established brand identity.

Maharashtra FDA says this is its first surrogate advertising examination

The Maharashtra FDA has described the action as the first time it has specifically begun examining surrogate advertising in this manner.

The regulator says the advertisement’s presentation, dialogue, product name and market context collectively raise a serious question about indirect promotion. That approach is important because it moves the scrutiny beyond the literal description of the advertised product.

Instead of assessing only whether an advertisement claims to sell elaichi, regulators can examine whether the overall campaign functions as a reminder of another restricted product carrying the same brand identity.

The FDA’s position is still an allegation at this stage. The actors’ responses and any subsequent regulatory proceedings will determine how the matter develops.

What Maharashtra’s pan masala ban means

Maharashtra has prohibited gutkha and pan masala containing tobacco or nicotine for years, with the state’s restrictions dating back to 2012. The current enforcement drive has brought renewed attention to the manufacture, storage, transportation, distribution and sale of prohibited products.

The FDA’s current action follows a broader enforcement campaign led by Commissioner Tukaram Mundhe. The regulator has been targeting networks involved in the distribution and sale of banned gutkha, tobacco and nicotine-containing pan masala.

The FDA’s official portal has also reported recent enforcement activity involving raids, arrests and seizures of prohibited food products. The regulator has said that it is working with police agencies in cases involving organised networks dealing in banned tobacco-related products.

This broader enforcement environment provides important context for the notices issued to the Bollywood actors. The action is not an isolated dispute over a celebrity advertisement; it forms part of a wider effort to restrict the availability and promotion of products prohibited under state food-safety rules.

Which laws has the FDA cited?

The Maharashtra FDA has invoked provisions of the food safety and Standards Act, 2006 in examining the advertisement.

One of the provisions cited is Section 24, which deals with restrictions on advertisements of food and prohibits advertisements that are misleading or deceptive. The regulator has also referred to Section 53, which provides for a penalty of up to Rs 10 lakh for a person WHO is party to the publication of a misleading advertisement concerning food.

The existence of a maximum statutory penalty does not mean that the three actors have already been fined Rs 10 lakh each. The notices begin a process in which the regulator will consider the explanations and other material supplied by the parties before deciding what action, if any, is appropriate.

This distinction matters because a show-cause notice is not itself a final finding of wrongdoing. The FDA is asking the actors to explain their involvement and address the regulator’s concerns.

Why the endorsement contracts matter

The FDA’s request for the actors’ endorsement contracts and campaign documents could become important in determining how responsibility is assessed.

Celebrity advertising involves several parties, including the brand owner, advertising agencies, production teams and the public figures appearing in the campaign. The terms of an endorsement agreement can indicate what the celebrity was contracted to promote and the extent of their involvement in the campaign.

The regulator has also requested remuneration details and evidence of due diligence. These documents could help establish the circumstances in which the advertisement was approved and produced.

For celebrities, the case highlights a broader issue in advertising: whether an endorser can rely entirely on the advertiser’s representations when a product or brand operates in a legally sensitive category.

Why celebrity endorsements are under greater scrutiny

The involvement of Shah Rukh Khan, Ajay Devgn and Tiger Shroff gives the dispute an unusually high profile. All three are among India’s most recognisable film personalities, meaning their appearance in an advertisement can significantly increase its reach and visibility.

That influence is one reason regulators and consumer advocates have increasingly focused on celebrity endorsements. A celebrity does not merely display a product; their public reputation can become part of the marketing message.

Maharashtra FDA Commissioner Tukaram Mundhe has previously indicated that celebrities should ensure that products they advertise comply with applicable norms and that misleading or false advertising can attract legal consequences.

The current notices put that principle into practice by asking the three actors to explain their roles rather than treating the endorsement as an issue solely between the advertiser and regulator.

Vimal advertising has faced scrutiny before

The latest Maharashtra action is not the first time Vimal-related advertising involving Bollywood stars has attracted regulatory or legal attention.

In 2025, a consumer forum in Jaipur issued notices to Shah Rukh Khan, Ajay Devgn and Tiger Shroff, along with the manufacturer, in connection with an alleged misleading Vimal Pan Masala advertisement. That matter concerned a claim associated with saffron and whether the advertisement could mislead consumers.

Earlier scrutiny has also focused on whether Vimal Elaichi advertising could function as a form of surrogate promotion. In 2019, for example, the Maharashtra public Health authorities sought trademark information concerning Vimal branding while examining whether an advertisement presented as a mouth freshener could indirectly promote tobacco products.

The history shows why the latest FDA action has broader significance. The question of how brands associated with restricted tobacco products can advertise legally marketable products has been debated for years.

The difference between a legal product and its brand association

One of the more complicated aspects of the case is the distinction between the product named in an advertisement and the wider brand identity surrounding it.

Elaichi itself is not the issue identified by the FDA. The regulator’s concern is that consumers may associate the Vimal name with pan masala and that advertising another Vimal-branded product could therefore maintain or strengthen that association.

That creates a difficult regulatory question. If a company legally sells one product while another product carrying the same brand is prohibited, regulators must determine whether advertising the legal product is a genuine marketing exercise or an indirect way of keeping the restricted brand visible.

The FDA’s examination of the advertisement’s dialogue, presentation and market context suggests that it intends to consider the campaign as a whole rather than focusing on a single product description.

What the notices mean for the three actors

What could happen after the FDA notices?

The immediate next step is for the three actors to respond to the show-cause notices. Their explanations could address what product they believed they were endorsing, the terms of their agreements, the nature of the campaign and any due diligence carried out before participation.

The FDA will then have to assess the responses and supporting documents. Depending on its findings, the matter could proceed to further regulatory or legal action, or the allegations could be addressed through the responses provided.

At this point, it would be premature to conclude that the actors have violated the law. The regulator has raised a prima facie concern and is seeking explanations. A final determination would require consideration of the evidence and the parties’ responses.

Why this case could affect celebrity advertising

The case could have implications beyond the three actors and the Vimal brand if Maharashtra’s FDA establishes a stronger precedent for examining surrogate advertising.

Advertisers operating in categories connected to restricted products may face greater pressure to demonstrate that their campaigns promote only the legal product and do not indirectly reinforce the identity of a prohibited one.

Celebrity endorsers could also face increased scrutiny over the products and brands they agree to promote. The FDA’s request for due-diligence records suggests that the regulator is interested in understanding how endorsement decisions were made, not merely who appeared on screen.

For the advertising industry, the practical lesson is that a legally saleable product may not automatically shield an entire campaign from regulatory examination when its branding is closely linked to a prohibited product.

Maharashtra’s crackdown puts surrogate advertising in focus

The notices issued to Shah Rukh Khan, Ajay Devgn and Tiger Shroff mark a new phase in Maharashtra’s enforcement campaign against tobacco and nicotine-containing gutkha and pan masala. The state’s FDA is now examining not only the sale and distribution of prohibited products but also the promotional mechanisms that can keep their brands visible.

The Vimal Elaichi advertisement has become the test case because of the brand’s association with pan masala and the participation of three high-profile Bollywood stars. The FDA’s decision to seek contracts, campaign material and due-diligence records indicates that the regulator intends to examine the wider circumstances behind the endorsement.

For now, the three actors have been asked to explain their roles, and no final finding of liability has been established through the notices themselves. The next stage will depend on their responses and the evidence reviewed by the Maharashtra FDA.

Whatever the eventual outcome, the case has reopened a long-running question in Indian advertising: when does promotion of a legal product become indirect promotion of a restricted one? With Maharashtra’s regulator now explicitly examining surrogate advertising, the answer could have consequences for brands, advertising agencies and celebrities far beyond the Vimal campaign.