Magine discovering your likeness misused in explicit deepfakes Aishwarya Rai Bachchan recently did.. On her phone were links to pornographic deepfakes with her face, fake websites naming her as “chairperson,” and AI-generated videos placing her in intimate situations she had never been part of.
Welcome to 2025. Being a celebrity today is not just about navigating scripts, endorsements, and fans. It is about constantly fighting for control over your own digital existence and protecting your own dignity.
The Big Questions of 2025
This year has become a watershed moment for personality rights in India. The Delhi High Court has unexpectedly turned into a digital rights fortress. Hon’ble Judges now face questions that once sounded like science fiction:
- Can artificial intelligence steal your identity?
- Who owns your digital likeness?
- How do you fight an enemy that can recreate you, sometimes more convincingly than you can recreate yourself?
Bollywood at Ground Zero
The entertainment industry has become the frontline of this digital war. Bollywood celebrities are battling:
- Sexually explicit deepfakes
- Fake endorsements and merchandise scams
- AI chatbots mimicking their personalities without consent
What makes this wave terrifying is its sophistication. Deepfakes are no longer crude or laughably fake. They are often indistinguishable from reality. And thanks to cheap apps, anyone can create one in minutes. It started with the veteran actor Anil Kapoor approaching the Delhi High Court to safeguard not just his image[AM1] , but his expressions, gestures, voice, and even iconic dialogues. The court granted him a sweeping injunction prohibiting unauthorised use of his name and likeness, his voice and speech patterns, iconic catchphrases like “Jhakaas” and AI-generated content replicating his identity. Justice Prathiba M. Singh, in her order, recognised that an actor’s body of work is an asset and misuse in digital spaces, especially through AI, can cause irreparable harm to both dignity and legacy.
The Bachchan Breakthrough
Aishwarya Rai Bachchan: Drawing Digital Lines
In Aishwarya Rai Bachchan v. Aishwaryaworld.com & Ors.[1] filed September 9, the actress confronted:
- AI pornographic content using her likeness
- Fake corporate associations
- Unauthorized merchandise with her name
- Deepfake “intimate” images
Within 72 hours, the court ordered takedowns. Justice Karia emphasised it would not “turn a blind eye” to exploitation. The ruling made three big contributions:
- Dignity as a Fundamental Right – Personality misuse violates privacy and the right to live with dignity and integrity.
- Economic Harm Recognition – Unauthorised use causes both reputational and financial harm.
- Technology-Neutral Protection – Protection applies regardless of whether harm was caused by AI, Photoshop, or other tech.
Abhishek Bachchan: Parallel Protection
A day later, Abhishek Bachchan vs The Bollywood Tee Shop & Ors [2]sought relief against:
- AI videos creating false narratives
- Forged signatures
- Sexually explicit fakes
- False endorsements
The court granted parallel protection, signalling that identity theft was not an isolated issue but a systemic, industry-wide problem.
Beyond the Bachchans: Expanding Circles
Karan Johar: Protection vs. Parody[3]
Karan Johar’s case forced the court to balance protection with free speech:
- Fake endorsements and merchandise were prohibited
- Satire, memes, and parody were explicitly protected
This nuanced approach showed that courts are aware personality rights cannot come at the cost of expression or fake creations.
Nagarjuna: South Indian Superstar Joins the Fight
On September 25, Telugu superstar Nagarjuna Akkineni won protection against:
- Pornographic deepfakes
- Fake merchandise
- AI clones trained on his likeness
The court’s recognition of his decades-long career showed that personality rights extend beyond Bollywood, covering all public figures whose dignity and reputation are at stake.
“Dynamic Plus” Injunctions- the Legal Game-Changer
The most revolutionary tool to emerge this year is the dynamic plus injunction, first tested in Sadhguru Jagadish Vasudev v. Rogue Websites & Ors.[4]
Unlike ordinary injunctions[AM2] , which tackle specific violations, dynamic plus injunctions are:
- Forward-Looking – They provide automatic protection against future violations.
- Platform-Agnostic – They apply across all mediums and platforms.
- AI-Specific – They protect voice, likeness, attire, and even vocal style.
- Government-Integrated – They allow enforcement with the help of the Ministry of Electronics and IT (MeitY).
Justice Banerjee’s reasoning was clear: “The rights of a plaintiff cannot be rendered otiose in this world of rapidly developing technology.”
Fighting Digital Hydras
Stopping deepfakes is like battling a digital hydra. Cut off one head, and two more appear.
- The speed gap is stark. Law develops incrementally, but AI evolves exponentially. Courts issue injunctions post-violation, while AI models can produce thousands of fakes in hours.
- By the time courts crafted the dynamic plus framework in 2025, AI had already leapt ahead, generating convincing fakes from a single photo.
- Globally, the same struggle plays out. The European Union’s AI Act, once hailed as revolutionary, was outdated by the time it came into force.
Conclusion: Fighting with Realism, Not Illusion
As we navigate this deepfake dilemma, one thing becomes clear: the fight for personality rights in India isn’t just about protecting celebrities. It’s about preserving the very concept of individual identity in an artificially intelligent world. The Delhi High Court’s innovations in 2025 may well be remembered as the moment when law began catching up with technology’s most profound challenges to human dignity.
However, we cannot eliminate deepfakes entirely. The goal is resilience, not perfection.
- Law can deter misuse and protect dignity.
- Technology can authenticate truth and detect lies.
- Society must adapt with critical awareness.
The next step lies in a collaborative framework between courts, tech companies, and regulators. This fight is not only about celebrities. It is about the survival of identity itself in an age where algorithms can rewrite reality.
The hydra may be immortal, but so is human adaptability. And that eternal struggle, between deception and dignity and between speed and stability, defines our digital age.
[1] CS(COMM) 956/2025)
[2] (CS(COMM) 960/2025)
[3] CS(COMM) 974/2025
[4] CS(COMM) 578/2025
[AM1]This section is strong. You may add the citation of Anil Kapoor v. Simply Life India & Ors. (2023), since referencing the case name adds authority and traceability.
[AM2]you could enrich this by mentioning how these differ procedurally from John Doe or Ashok Kumar injunctions – in just a small para.
Authored By: Mr. Aayush Sinha, Managing Associate at S. Majumdar & Co. and Ms. Manya Jain, Associate at S. Majumdar & Co.
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