The Bombay High Court has granted interim protection to actor Preity Zinta in her suit seeking enforcement of her personality, publicity and moral rights against Google LLC, Meta Platforms, X, YouTube and several online intermediaries, directing the removal and blocking of AI-generated deepfakes, fake chatbot personas, manipulated images, GIFs and other unauthorised digital content exploiting her identity without consent.
The single-judge Bench of Justice Madhav J Jamdar held that Zinta had established a strong prima facie case for the grant of interim relief. The Court observed that the unauthorised creation, publication and circulation of AI-generated deepfakes, morphed images, superimposed videos and other manipulated digital content using the actor’s identity constituted a prima facie infringement of her personality rights, publicity rights and moral rights. The interim injunction shall remain in force until further orders.
According to the plaint, Zinta’s identity has been extensively misappropriated across multiple digital platforms through AI-generated deepfake videos, morphed photographs, voice simulations, chatbot personas, unauthorised merchandise, GIFs, manipulated images and other digital content falsely suggesting her endorsement, sponsorship or association.
The suit identifies more than 275 infringing URLs hosted on platforms including YouTube, Facebook, Instagram and X, besides websites, domain names and AI-powered services allegedly exploiting her identity for commercial gain. Zinta contended that her name, image, likeness, distinctive smile, voice, mannerisms, caricatures and overall public persona are valuable proprietary and commercial attributes over which she enjoys exclusive personality and publicity rights.
She argued that the unauthorised commercial exploitation of these attributes amounts to misappropriation of her identity, causes dilution of her goodwill and reputation, and infringes her moral rights under Section 38-B of the Copyright Act, 1957. The plaint also sought protection against identified online intermediaries as well as unknown persons impleaded as John Doe defendants.
After examining the material placed on record, the Court found that the plaintiff had demonstrated extensive misuse of her identity through AI-generated deepfakes, manipulated photographs, superimposed videos, chatbot services enabling users to interact with AI-generated personas purporting to represent her, and the online sale of unauthorised merchandise bearing her name and likeness.
The Court observed that such unauthorised digital exploitation was capable of deceiving the public, commercially exploiting the actor’s reputation and causing irreversible injury to her public image.
Justice Jamdar further observed that once AI-generated deepfake material is uploaded and disseminated on the internet, it can be replicated, redistributed and reproduced indefinitely, making the resulting injury to an individual’s personality rights and reputation difficult to reverse. The Court held that such misuse warranted immediate judicial intervention to prevent continuing infringement.
The High Court reiterated that personality and publicity rights derive constitutional protection from Articles 19(1)(a) and 21 of the Constitution, which encompass the right to freedom of speech and expression, privacy, dignity and personal autonomy. It further held that the unauthorised exploitation of the actor’s identity also prima facie affected her moral rights protected under the Copyright Act.
Referring to Rule 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the Court noted that intermediaries are under a statutory obligation to exercise due diligence while addressing unlawful and infringing content hosted on their platforms.
During the hearing, the Court also orally cautioned technology companies and digital intermediaries regarding the growing misuse of artificial intelligence. It observed that global technology platforms must take greater responsibility to curb misuse of their services and ensure that their platforms are not used to violate the fundamental rights of individuals.
Accordingly, the Court directed Google, YouTube, Meta, X and other intermediaries to remove, block or disable access to the identified infringing URLs within 72 hours.
It further directed the platforms to act upon future infringing URLs notified by the plaintiff within the same time frame, while granting them liberty to seek appropriate directions from the Court if any notified content was believed to be genuine or non-infringing.
The High Court also restrained the defendants, including unknown persons, from creating, publishing, circulating, reproducing, distributing or commercially exploiting Zinta’s name, image, likeness, voice, persona, distinctive attributes or other identifying features through AI chatbots, digital avatars, deepfakes, face-morphing technology, GIFs, manipulated videos or any similar artificial intelligence-based tools without her express authorisation.
In addition, the Court directed certain digital platforms to disable AI-generated characters created using the actor’s identity, prevent the creation of fresh AI personas bearing her name, image or voice, and directed domain name registrars to disclose registration details of persons operating websites hosting infringing content whenever required in accordance with law.
Noting that the defendants had not opposed the grant of interim protection but had expressed practical concerns regarding future takedown requests, the Court clarified that intermediaries would be at liberty to raise objections if any notified URL contained legitimate or non-infringing content, and could approach the Court for appropriate directions. The matter has been listed for further hearing on September 3, 2026, with the ad-interim injunction continuing until further orders.
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