The Bombay High Court has granted interim protection to actor Samantha Ruth Prabhu in a case concerning allegedly unauthorised AI-generated deepfakes, morphed images, manipulated videos and other digital content using her identity and likeness.
A single-judge bench of Justice Milind Jadhav observed that Prabhu had established a “very strong prima facie” case for interim relief and protection of her personality rights.
The court’s order deals with content that Prabhu alleged had been created or circulated without her consent, including manipulated photographs and videos, AI-generated voice simulations and other digital material.
Court Says Prabhu’s Personality Rights Were Prima Facie Violated
According to the court, the material placed before it indicated that Prabhu’s personality, publicity and moral rights had been affected by the creation and dissemination of morphed, deepfake and superimposed content.
“The material on record clearly shows that the plaintiff’s personality rights, publicity rights, and moral rights are violated by creation of morphed, deepfake and superimposed contents comprising the morphed image, photographs and videos,” the court observed.
The bench also referred to constitutional protections while considering the actor’s plea.
The court noted that personality and publicity rights in the circumstances were connected with Article 19(1)(a) of the Constitution, while the right to life and personal liberty under Article 21 includes protection of privacy.
It further observed that Prabhu’s right to live with dignity had been affected and said her moral rights under the Copyright Act had also been prejudicially impacted.
Samantha Ruth Prabhu Sought Protection From Unauthorised Digital Content
Prabhu approached the court after allegedly discovering a range of digital material that used elements of her identity without her permission.
According to her case, the material included AI-generated deepfake videos, manipulated photographs, simulated versions of her voice, chatbot personas and merchandise incorporating aspects of her persona.
She alleged that some of the content was misleading, defamatory, explicit or otherwise objectionable and argued that its circulation could damage her dignity, reputation and goodwill.
The actor sought permanent injunctions preventing social media platforms and other entities from hosting, publishing or commercially exploiting the unauthorised material.
Her pleas included directions concerning platforms such as Facebook and Google, as well as Amazon in relation to third-party listings. She also sought relief against traders allegedly using her photographs and other aspects of her persona to market products, along with pornographic websites.
Court Refers to Earlier Preity Zinta and Shruti Haasan Case
During the proceedings, the court referred to an earlier order involving actors Preity Zinta and Shruti Haasan concerning similar issues.
The bench also questioned the defendants about the legal obligation applicable to platforms in dealing with such content.
“What’s the provision that casts duty on you?” the court asked, while noting that the proceedings involved protection of the fundamental right to privacy.
The defendants did not contest the reliefs sought at the hearing and informed the court that they were already examining the posts and digital material identified in the case.
Interim Relief Granted to Samantha Ruth Prabhu
Following the submissions, the Bombay High Court granted interim relief to Prabhu.
The defendants have been directed to file their affidavits within six weeks. The ad-interim protection granted to the actor will continue until further orders from the court.
The proceedings therefore remain ongoing, and the interim order should not be treated as a final adjudication of every allegation or as a final determination of liability against each defendant.
Why the Case Matters for AI Deepfake Content
The case comes amid growing legal and public concerns surrounding the use of artificial intelligence to create realistic but unauthorised images, videos and audio involving public figures.
For actors and other public personalities, such material can extend beyond conventional image manipulation because generative AI can reproduce a person’s appearance or voice in increasingly realistic ways.
The Samantha Ruth Prabhu case places questions surrounding personality rights, privacy, dignity and the circulation of AI-generated content before the court, with further proceedings expected after the defendants file their affidavits.
