Bombay High Court blocks AI deepfakes of Samantha Ruth Prabhu

The Bombay High Court on October 1 restrained the unauthorised use of actor Samantha Ruth Prabhu's name, image and voice and ordered the removal of AI-generated deepfakes and morphed content built from her identity, in an interim order that covers 18 defendants.

Justice Madhav Jamdar passed the ad-interim relief while hearing a suit filed by Prabhu for protection of her personality and publicity rights, according to Bar & Bench. The case is styled Samantha Ruth Prabhu v. John Doe and Others. Named parties include Meta Platforms, which operates Facebook and Instagram; Google, which operates YouTube; Amazon; several AI platforms and digital media outlets; and unidentified John Doe defendants, per the Free Press Journal's account. The Ministry of Electronics and Information Technology and the Department of Telecommunications were added so the court's directions can be enforced.

Prabhu's advocate, Rashmin Khandekar, told the court that her identity was being used across websites, social platforms and pornographic portals, and that her photographs were being morphed into obscene videos, images and audio clips through AI tools. He also pointed to interactive AI chatbots that used her identity, per PTI's report and Moneycontrol. The claims are allegations in a suit, and the court's order rests on the material it found prima facie.

The reasoning is the part that matters beyond this case. The court held that Prabhu's personality and publicity rights are protected by Article 19(1)(a) of the Constitution, which covers freedom of speech and expression, and by Article 21, which covers life, personal liberty, privacy and human dignity. Her moral rights as a performer are separately protected under Section 38B of the Copyright Act. "All these valuable rights of the plaintiff (Ruth) are violated and adversely affected by the actions of the defendants," the bench said, per India Today. The order also refers to the due-diligence duty intermediaries carry under Rule 3 of India's Information Technology Rules, 2021.

Prabhu had also sought permanent injunctions, damages and a John Doe order, which allows action against unidentified infringers. She was granted leave under Clause XII of the Letters Patent on August 28, which the court uses where defendants or causes of action sit outside its ordinary territorial jurisdiction; she argued her goodwill is based in Mumbai while several alleged infringers operate elsewhere.

For creators, an interim injunction is a hold, not a verdict on the technology. It restrains circulation of content built from one person's likeness and voice, and it names no model or generator as the cause. The outcome that will matter is the one at the end of the case, not this order.

The suit is listed for further hearing on December 10.