Mumbai: Actor Samantha Ruth Prabhu has secured interim protection from the Bombay High Court against the unauthorised use of her name, image and voice by AI platforms, digital media entities and e-commerce portals.

Justice Madhav Jamdar, while hearing Samantha’s suit seeking protection of her personality rights, directed the removal of unauthorised content featuring the actor and restrained further misuse of her identity without permission. The court observed that the material placed before it prima facie indicated violations of Samantha’s personality and publicity rights through non-consensual AI-generated deepfakes and morphed content.

Court recognises personality and performers’ rights

Samantha had approached the Bombay High Court seeking protection against the creation and circulation of AI-generated, morphed and deepfake material using her identity.

In his observations, Justice Jamdar said Samantha’s personality and publicity rights are protected under Articles 19(1)(a) and 21 of the Constitution, while her moral rights as a performer receive separate protection under Section 38B of the Copyright Act.

The court’s interim order covers the unauthorised use of her name, image and voice and directs the removal of offending material. The order is an ad-interim relief, meaning the proceedings in the suit will continue and the matter has not reached a final determination.

Suit names 18 defendants

Samantha’s legal action covers unknown infringers as well as technology platforms, AI developers, digital media companies and e-commerce entities. The suit involves 18 defendants, including government bodies.

Among the reliefs sought by the actor were permanent injunctions, removal of infringing material, damages and a John Doe order. Such an order allows legal proceedings and enforcement measures against unidentified persons who may subsequently be identified as infringers.

The case specifically concerns alleged misuse of Samantha’s identity through AI-generated and manipulated material, including deepfakes.

Samantha cited Mumbai connection

On the question of jurisdiction, Samantha relied on Section 62 of the Copyright Act, 1957. Her claim concerning performers’ moral rights is based on Section 38B of the same legislation.

The actor was granted leave under Clause XII of the Letters Patent on August 28, allowing the Bombay High Court to hear the matter in circumstances involving defendants or causes of action beyond its ordinary territorial jurisdiction.

Samantha submitted that her business interests and goodwill are based in Mumbai, while several alleged infringing activities and commercial operations involving non-resident defendants extend beyond the court’s local jurisdiction.

Court orders removal of unauthorised content

Following the hearing, the court granted ad-interim relief directing the removal of the unauthorised content and restraining further unauthorised use of Samantha’s name, image and voice.

The order comes amid a growing number of personality-rights disputes involving AI-generated deepfakes and manipulated celebrity content. Bombay High Court has also recently dealt with similar pleas involving actors and other public figures seeking protection against unauthorised digital representations.

The Samantha matter is scheduled to come up for further hearing on December 10.