Bombay HC Grants Preity Zinta Ad-Interim Injunction Against Deepfakes, AI Chatbots and Unauthorised Merchandise

The Bombay High Court has restrained multiple defendants from exploiting Preity Zinta's name, image, voice, and persona through AI-generated deepfakes, chatbots, and merchandise without her consent.

Justice Madhav J. Jamdar, sitting singly at the Bombay High Court's Ordinary Original Civil Jurisdiction, granted a comprehensive ad-interim injunction on 8 July 2026 in favour of actor Preity G. Zinta, restraining sixteen defendants — including Google LLC, Meta's Instagram and Facebook, X (formerly Twitter), AI chatbot operators, a merchandise seller, GIF platforms, and unknown persons — from using any attribute of her personality without authorisation. The court found a strong prima facie case on the basis of approximately 275 infringing URLs and documentary exhibits showing AI-generated deepfakes, morphed photographs, voice simulations, chatbot personas, and merchandise bearing her name and likeness. The matter arises as a Commercial IP Suit, with the interim application amended on the day of the hearing itself before orders were pronounced.

The Dispute Before the Court

Zinta, who has worked in 42 films across a career spanning over 25 years and has received awards including the Filmfare Award for Best Female Debut (1999), Best Actress (2004), and the Silver Hugo Award for Best Actress at the Chicago International Film Festival (2008), filed a commercial suit asserting that her personality and publicity rights were being systematically exploited across digital platforms without her consent.

The plaint identifies six protectable “Personality Traits”: her name “Preity Zinta” and “Preity G Zinta”, her nicknames “PZ” and “PGZ”, her photograph and likeness including her distinctive dimpled smile, her voice and mannerisms, her caricature and any artistic representation of her image, and her overall public persona developed through cinema, sports ownership, and brand endorsements.

The defendants are spread across three functional categories. Defendant Nos. 1 to 3 operate major digital platforms — Google LLC and YouTube (Defendant No. 1), X (Defendant No. 2), and Instagram and Facebook (Defendant No. 3) — where infringing content had been uploaded and hosted. Defendant Nos. 4 to 11 operate AI chatbot services, AI image generation platforms, a merchandising website (Defendant No. 8, Kash Collective), and GIF hosting platforms. Defendant Nos. 12 to 15 are domain name registrars, impleaded for disclosure of the identities of unknown operators. Defendant No. 16 represents unknown persons who are already exploiting, or may in future exploit, the plaintiff's rights anonymously.

The Legal Basis Asserted

Senior Advocate Mr. Venkatesh Dhond, appearing for the plaintiff, grounded the claim on three overlapping legal foundations. Personality rights and publicity rights were said to flow from Article 19(1)(a) of the Constitution of India, which protects freedom of speech and expression. The right to privacy and the right to live with dignity were said to be protected under Article 21. Moral rights over the plaintiff's performances were asserted under Section 38-B of the Copyright Act, 1957.

Mr. Dhond also pointed to Rule 3(1)(b) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, which imposes due diligence obligations on intermediaries. He argued that this rule was inserted by a 2022 amendment and therefore post-dates the Supreme Court's judgment in Shreya Singhal v. Union of India (2015) 5 SCC 1, which had been decided in a different legislative context. The court noted that this provision had already been considered by the Bombay High Court in Akshay Hariom Bhatia v. John Doe & Ors., 2025 SCC OnLine Bom 4044.

On the question of irreparable harm, the court accepted the submission that monetary damages alone cannot adequately remedy the injury caused by deepfake content. Once such material is disseminated across the internet, it is capable of unlimited replication and circulation, causing permanent dilution of personality rights and public image. This reasoning — that the nature of digital propagation makes online personality rights violations categorically different from ordinary commercial torts — underpinned the court's decision to grant ad-interim relief rather than wait for a full hearing on the merits.

What the Exhibits Showed

Exhibit-K to the plaint contained a list of approximately 275 URLs across YouTube, Facebook, Instagram, and X hosting allegedly infringing content. Mr. Dhond conceded that Serial No. 12 on that list had been wrongly included and sought its exclusion from any orders passed.

Exhibits L through V (pages 152 to 192 of the plaint) contained images and screenshots that the plaintiff's counsel described as AI-generated deepfakes, morphed images, and superimposed content using the plaintiff's likeness without authorisation. Specific exhibits were mapped to specific defendants: Exhibit O to Defendant No. 4, Exhibit Q to Defendant No. 6, Exhibit S to Defendant No. 9, Exhibit V to Defendant No. 11, Exhibit T to Defendant No. 10, and Exhibit P to Defendant No. 5.

The plaintiff also placed on record that Defendant No. 5 hosted AI-generated “Characters” using her name and image, that Defendant No. 8 (Kash Collective) was selling merchandise bearing her name, image, and likeness, and that certain AI chatbot platforms permitted members of the public to interact with personas purporting to be her — generating responses over which she exercises no control whatsoever.

How the Court Reasoned

Justice Jamdar noted that counsel for the defendants had not opposed the reliefs sought, but flagged practical difficulties regarding future URLs that the plaintiff might notify. Defendants indicated they could comply with the takedown of the URLs in Exhibit-K without difficulty. The court recorded the defendants' position that if future URLs notified by the plaintiff contained genuine photographs or non-infringing material, they would communicate detailed objections to the plaintiff's advocates, who could then approach the court for further orders. Liberty was granted to both sides for that purpose, consistent with the due diligence framework under Rule 3 of the IT Rules, 2021.

The court found that the material on record clearly established a violation of personality rights, publicity rights, and moral rights through morphed, deepfake, and superimposed content. It held that the right to life under Article 21 includes the right to live with dignity, and that the impugned actions directly affected that right. The moral rights claim under the Copyright Act was treated as a consequence that followed from the same factual matrix.

Counsel for Defendant Nos. 1 and 9 informed the court that Tenor Inc. (Defendant No. 9), a GIF platform, is wholly controlled by Google LLC (Defendant No. 1), and that compliance with the order against Defendant No. 9 would be handled by Google.

Directions Issued

The court granted ad-interim relief in terms of amended prayer clauses (a) to (e-5). The principal directions are as follows:

Defendant Nos. 4, 8 to 11, and 16 are restrained by temporary injunction from using, exploiting, or misappropriating the plaintiff's Personality Traits — including her name, nicknames, photograph, image, likeness, distinctive dimpled smile, caricature, voice, and mannerisms — through any technology, including AI, generative AI, machine learning, deepfakes, face morphing, GIFs, AI chatbots, digital avatars, and voice cloning, across any medium or format.

Defendant Nos. 4, 8 to 11, and 16 are separately restrained from violating her moral rights by unauthorisedly distorting, mutilating, or modifying her performances, including through AI videos, GIFs, and images.

Defendant Nos. 1 to 3 are directed to take down, remove, or block access to all URLs in Exhibit-K (excluding Serial No. 12) within 72 hours of this order being uploaded on the court's website. They are further directed to action any additional infringing URLs of a similar nature notified by the plaintiff or her authorised representative within 72 hours of such notification.

Defendant Nos. 4, 6, 9, and 11 are directed to remove or block content identified in Exhibits O, Q, S, and V respectively within 72 hours. Defendant No. 10 is directed to remove content in Exhibit T within 72 hours, excluding content on the plaintiff's own official verified channel listed in Exhibit U. Defendant No. 5 is directed to remove Characters identified in Exhibit P within 72 hours and, separately, to add the names “Preity Zinta” and “Preity G Zinta” to its character creation and search blocklists to prevent creation of new characters using those names and to block search results for those names.

Defendant Nos. 8 and 16 are restrained from passing off their goods or services as those emanating from or endorsed by the plaintiff by using her Personality Traits for any commercial or personal gain.

Defendant Nos. 12, 13, 15, and 16 are directed to disclose, within 7 days of a written request accompanied by an affidavit from the plaintiff specifying the impugned domain name and manner of infringement, the complete particulars of the registrants of any domain names hosting infringing content.

Outcome

The ad-interim relief is to continue until further orders. The defendants are directed to file their affidavits in reply within six weeks from 8 July 2026. Rejoinder affidavits, if any, are to be filed within two weeks thereafter. The matter has been listed for further hearing on 3 September 2026. The plaintiff's prayer clauses as amended on the date of the hearing were marked as Exhibit ‘X’ and taken on record, with re-verification dispensed with.