The Bombay High Court has granted interim protection to actor Samantha Ruth Prabhu against the unauthorised use of her name, photographs, voice, likeness and other personality attributes through deepfakes, morphed images, AI-generated content and other digital material.
Justice Madhav Jamdar passed the order on October 1 after Samantha approached the Court seeking protection of her personality and publicity rights.
The Court directed Google, Meta Platforms and other online intermediaries to remove identified objectionable material and restrained unknown defendants from continuing to create or circulate content that misuses her identity.
The order covers deepfake videos, morphed photographs, AI-generated voice clips and other material allegedly created or published without her consent.
FCRF Launches CP-FRM to Build India’s Next Generation of Fraud Risk Professionals
Samantha Told Court Her Face, Voice and Identity Were Being Misused
Samantha’s lawyer, Rashmin Khandekar, told the Court that her image and personality were being used across websites, social-media platforms, pornographic portals and AI-based services without authorisation.
The material placed before the Court allegedly included morphed photographs, obscene videos, manipulated images and AI-generated audio.
Her plea argued that such content did more than misuse her celebrity status for commercial gain.
It also allegedly placed her in fabricated situations, created false associations and damaged her dignity, privacy and reputation.
The suit sought protection over elements closely associated with her identity, including her name, photograph, voice, likeness and other recognisable aspects of her persona.
It also sought removal of existing material and restrictions on future unauthorised use.
High Court Links Personality Rights With Privacy and Dignity
The Bombay High Court made a broader legal observation while granting interim relief.
Justice Jamdar said Samantha’s personality rights were connected with constitutional protections, including freedom of speech and expression under Article 19(1)(a) and the rights to life, privacy and dignity under Article 21.
The Court found, at the interim stage, that the material placed before it showed violations of her personality, privacy and moral rights.
It also noted that performers have separate protections under copyright law.
On that basis, the Court concluded that Samantha had made out a strong prima facie case for immediate relief.
The ruling is significant because Indian law does not contain one single statute called a “personality rights law”.
Instead, courts have developed protection through a combination of privacy, publicity, passing-off, copyright and constitutional principles.
Platforms Ordered to Remove Objectionable Content
The Court directed online platforms to act against the material identified in Samantha’s suit.
Google, Facebook and other intermediaries were ordered to remove or block access to objectionable content featuring her.
Justice Jamdar also referred to Rule 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
That rule requires online intermediaries to exercise due diligence while handling unlawful or harmful content.
The Court stressed that such obligations become particularly important when the material concerns fundamental rights and unauthorised use of a person’s image or identity.
The interim order does not amount to a final determination of every claim in the lawsuit.
The matter will continue to be heard, and defendants will have an opportunity to respond.
What Are Personality Rights?
Personality rights broadly refer to a person’s ability to control commercial or unauthorised exploitation of identifiable aspects of their persona.
For a public figure, this can include their name, face, voice, signature, likeness or other characteristics that allow people to identify them.
The rise of generative AI has made these disputes more complicated.
A deepfake can recreate someone’s face or voice without the person ever participating in the recording.
This can create fake endorsements, fabricated conversations, sexualised material or misleading videos that appear realistic enough to deceive viewers.
For celebrities, such misuse can also create commercial harm because their image and voice have economic value in advertising, films and endorsements.
Samantha Joins Growing List of Public Figures Seeking Court Protection
Samantha’s case is part of a wider series of personality-rights disputes reaching Indian courts.
In recent months, actors and public figures including Preity Zinta, Sonakshi Sinha, Varun Dhawan and Yuvraj Singh have obtained or sought injunctions against deepfakes, AI-generated impersonation and unauthorised use of their names, voices and likenesses.
These cases show how Indian courts are increasingly adapting existing legal principles to deal with AI-generated impersonation.
The central concern is no longer limited to unauthorised photographs.
Modern cases can involve synthetic audio, fake videos, chatbot personas, manipulated advertisements and digitally generated sexual content.
Courts are therefore being asked to define how far an individual’s control over their identity extends when technology can recreate that identity at scale.
Deepfakes Create New Risks Beyond Celebrity Reputation
The legal problem extends beyond film stars.
The same technology used to place an actor’s face in a fake video can also be used for financial fraud, impersonation and extortion.
Cybercriminals have already used cloned voices and manipulated videos to impersonate company executives, relatives and public officials.
When viewers believe such material is genuine, it can affect financial decisions, reputation and personal safety.
Samantha’s petition therefore sits within a much broader debate over how platforms, courts and regulators should respond when AI tools make impersonation faster and more convincing.
The Bombay High Court’s interim order focuses on protecting her individual rights, but its reasoning adds to an expanding body of Indian case law dealing with AI-generated identities.
What this means for you
AI-generated content using a real person’s face or voice is not automatically lawful simply because it was created digitally. Individuals whose identity is used without consent may seek removal, injunctions and other legal remedies, particularly where the material is deceptive, obscene or commercially exploitative.
Follow for daily updates on cybercrime, corporate fraud, DFIR, hacking, investigations, and digital forensics
