Relief to Preity Zinta as Bombay High Court orders takedown of specified deepfakes, AI-generated content

The Bombay High Court has granted Bollywood actor Preity Zinta interim protection against the proliferation of AI-generated deepfake and morphed content, ordering the immediate takedown of specified objectionable posts. This landmark ruling, in the case of *Preity Zinta v. Google LLC & Ors*, underscores the violation of an individual's personality, publicity, and moral rights, which are rooted in the fundamental rights to freedom of speech and expression (Article 19(1)(a)) and the right to life with dignity (Article 21) of the Indian Constitution. The Court also issued a stern reminder to online intermediaries, including Google and Meta, emphasizing their active obligation to exercise due diligence under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and to prevent the misuse of their platforms, rather than acting as mere passive conduits.

In a significant development for digital rights and the burgeoning challenge of artificial intelligence (AI) misuse, the Bombay High Court recently delivered an interim order in favour of Bollywood actor Preity Zinta. The Court directed various online platforms and intermediaries, including tech giants Google and Meta, to promptly remove specified AI-generated deepfake videos, morphed images, and chatbot-style interactions that unlawfully depicted the actor. This ruling, in the case of *Preity Zinta v. Google LLC & Ors*, marks a crucial step in India's evolving jurisprudence on personality rights and intermediary liability in the age of generative AI.

The interim relief granted to Ms. Zinta highlights the judiciary's proactive stance in safeguarding individual dignity and reputation against the deceptive capabilities of deepfake technology. It reinforces the principle that online platforms bear a significant responsibility to curb the dissemination of harmful content, moving beyond a passive role to actively ensure compliance with legal and ethical standards. This decision not only offers immediate succour to the aggrieved celebrity but also sets an important precedent for how Indian courts will address the complex interplay between technological advancement, fundamental rights, and the obligations of digital intermediaries.

The legal framework governing personality rights, publicity rights, and moral rights in India is not encapsulated in a single statute but has largely evolved through judicial pronouncements, drawing heavily from constitutional guarantees. Personality rights, encompassing an individual's right to control the commercial use of their identity, including name, image, likeness, and voice, are considered to flow from Article 21 of the Constitution, which protects the right to life and personal liberty, and implicitly, the right to live with dignity. Landmark judgments such as *R. Rajagopal v. State of Tamil Nadu* and *Justice K.S. Puttaswamy v. Union of India* have affirmed the right to privacy, including informational privacy and the control over one's persona, as fundamental rights.

Publicity rights, a commercial facet of personality rights, specifically protect against the unauthorised commercial exploitation of a celebrity's identity. Additionally, moral rights, as enshrined in Section 57 of the Copyright Act, 1957, grant authors and performers the right to claim authorship of their work and to restrain or claim damages in respect of any distortion, mutilation, modification, or other act in relation to their work that would be prejudicial to their honour or reputation. While the Copyright Act primarily protects original works, courts have extended its principles to safeguard performers' rights against the misuse of their likeness and performances.

The role of online intermediaries is primarily governed by Section 79 of the Information Technology Act, 2000 (IT Act), which provides a 'safe harbour' from liability for third-party content, provided they observe due diligence. This safe harbour is conditional upon adherence to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (IT Rules, 2021). Rule 3 of these Rules mandates intermediaries to establish grievance redressal mechanisms and expeditiously remove unlawful content upon notification. Recent amendments to the IT Rules in February 2026 have further strengthened these obligations, introducing a statutory definition of 'deepfake', drastically reducing the takedown timeline for such content to three hours, and mandating technical disclosure and traceability measures for AI-generated content. Indian courts have consistently granted similar interim relief to other celebrities, including Kartik Aryan, Shatrughan Sinha, Shilpa Shetty, Akshay Kumar, Suniel Shetty, Asha Bhosale, Arijit Singh, Amitabh Bachchan, Anil Kapoor, and Aishwarya Rai Bachchan, against the unauthorised use of their persona, particularly in the context of AI-generated content.

Preity Zinta's suit specifically targeted videos, images, and chatbot-style interactions that depicted her without permission through AI-generated deepfakes and morphed visuals. Her legal team, led by Senior Advocate Venkatesh Dhond, argued that such content infringed upon her personality, publicity, and moral rights, and also eroded her goodwill and professional reputation built over a career spanning more than 25 years. The Bombay High Court, presided over by Justice Madhav Jamdar, found that a strong prima facie case had been established for the violation of these rights, explicitly stating that they flow from the fundamental rights enshrined in Articles 19(1)(a) and 21 of the Constitution.

A pivotal aspect of the Court's interim order was its strong admonition to online intermediaries. Justice Jamdar unequivocally stated that international organizations like Google and Meta cannot claim to be mere passive conduits. He emphasized their obligation to be more concerned about the misuse of their platforms and to take proactive action against offenders, warning that failure to do so would amount to facilitating the infringement of citizens' fundamental rights. This judicial directive aligns with and reinforces the due diligence requirements stipulated under Rule 3 of the IT Rules, 2021, which mandates intermediaries to remove unlawful content expeditiously upon notification.

The interim relief granted included a directive for the immediate takedown of the identified deepfake and morphed content. While Meta Platforms, a respondent in the suit, expressed willingness to remove the specific YouTube links cited by Ms. Zinta, it sought liberty to raise objections concerning future complaints if they involved genuine photographs or lawful material. This highlights the ongoing challenge of distinguishing between legitimate content and malicious deepfakes, and the need for clear guidelines and robust grievance redressal mechanisms.

This ruling is part of a broader trend in Indian courts, which have increasingly adopted a proactive stance against the misuse of AI-generated content. Several other celebrities have successfully obtained similar injunctions, demonstrating the judiciary's commitment to protecting individual identity and reputation in the digital realm. However, India still lacks a dedicated, comprehensive statute specifically addressing deepfakes, relying instead on a patchwork of existing laws, including the IT Act, Copyright Act, and constitutional provisions. This fragmented approach can present challenges, particularly for non-celebrities who may find it difficult to seek redress due to the commercial nature often associated with personality and publicity rights.

The recent amendments to the IT Rules in February 2026, which mandate a three-hour takedown window for deepfakes and require labelling of AI-generated content, represent a significant regulatory step towards addressing these gaps. The Bombay High Court's order in the Preity Zinta case serves as a judicial endorsement of the spirit behind these amendments, emphasizing the urgent need for platforms to implement robust content moderation and accountability measures to combat the rapid spread of synthetic media.

The Bombay High Court's interim order in *Preity Zinta v. Google LLC & Ors* is a powerful affirmation of an individual's fundamental rights in the face of rapidly advancing AI technology. It sends a clear message that the unauthorised creation and dissemination of deepfakes and morphed content will not be tolerated, and that such acts constitute a violation of personality, publicity, and moral rights. For legal practitioners, this ruling underscores the increasing importance of these rights and provides a strong basis for seeking expeditious interim relief against digital identity theft and manipulation.

This decision places a heightened onus on online intermediaries to proactively monitor and remove harmful AI-generated content, aligning with the enhanced due diligence obligations under the amended IT Rules, 2021. Practitioners advising platforms must ensure robust compliance mechanisms, including efficient grievance redressal and adherence to the shortened takedown timelines for deepfakes. While the Indian legal landscape for AI regulation is still evolving, this case, alongside other similar judicial interventions, signals a clear judicial intent to protect individuals from the perils of synthetic media. Lawyers should closely watch for further legislative developments, including potential dedicated deepfake laws, and the guidelines expected from the Bar Council of India regarding the use of AI in legal practice, as directed by the Supreme Court in a separate matter, which will further shape this critical area of law.