India has no standalone statute protecting personality rights. What it has instead is a body of case law, built largely in Delhi, that stitches the protection together from passing-off, the right to privacy, and the courts' inherent powers to mould relief. For most of its life this jurisprudence dealt with a familiar wrong — an unauthorised hoarding, a lookalike in an advertisement, a brand borrowing a famous catchphrase. The deepfake changed the scale of the problem without changing the law available to answer it.
The turn began with the Amitabh Bachchan order in late 2022, where the Delhi High Court granted an omnibus interim injunction restraining the world at large from using the actor's name, image, and voice for commercial gain. The significance was less the result than the form of the relief: an injunction not against named defendants alone, but against anyone who might commit the wrong — the John Doe, or "Ashok Kumar", defendant that Indian courts had until then reserved mostly for film piracy.
The Anil Kapoor matter in 2023 took the next step. The conduct complained of there was already recognisably modern — morphed images, AI-generated content, merchandise, even a domain name — and the Court's order extended to technological means of misuse, expressly including artificial intelligence tools. It also confirmed something practitioners had long argued: that the protectable elements of a personality go beyond name and photograph to voice, mannerisms, and signature expressions. When the order protects the way a man says a single word, the right has become genuinely expansive.
Orders protecting other public figures have followed, and the Bombay High Court has carried the logic to voice itself, restraining AI platforms from cloning a singer's voice — recognising, in effect, that a voice model is a commercial appropriation of the person even when no recording is copied.
Why the toolkit matters more than the doctrine
It is tempting to read these cases as a doctrinal story about whether India recognises a "right of publicity". The more useful reading is procedural. Deepfake harm is fast, anonymous, and distributed; by the time a named defendant is served, the content has been mirrored across a dozen platforms. The courts' practical response has been a package: John Doe defendants to cover the unidentified, dynamic injunctions that extend to mirror content without fresh motions, and takedown directions to intermediaries and registrars who are the only parties actually capable of swift compliance.
That package is what a client should care about. The doctrinal question in most matters is rarely close — blatant commercial misuse of a recognisable persona has consistently been restrained. The real contest is operational: how quickly relief can be obtained, how the order is worded so that platforms act on it, and how enforcement keeps pace when the infringing content reappears under a new handle the same evening.
Where the strain shows
Three pressure points are worth watching. First, the boundary with free expression — satire, parody, and news reporting all use real personas, and the broader the injunctions become, the more carefully courts will have to police that line. Second, the position of the non-celebrity: the cause of action is built on commercial goodwill, which leaves the ordinary victim of a deepfake relying on privacy and criminal law, a noticeably weaker position. Third, the intermediaries: the IT Rules already require expeditious removal of impersonation content, and the obligations around synthetically generated media have only been tightening — but the gap between a takedown obligation on paper and a takedown in practice is where most enforcement battles are now fought.
For clients, the practical advice is unglamorous: register what can be registered, document the commercial value of the persona before trouble arrives, and move quickly when it does. The courts have shown they will act, and act broadly. But every order in this line of cases was won by a claimant who came to court prepared to show exactly what was taken and exactly where it was appearing.