Introduction:

In the landmark case of Sudhir Chaudhary v. Meta Platforms & Ors., the Delhi High Court, on October 10, 2025, delivered an interim order that reaffirmed the evolving jurisprudence surrounding personality rights and the threat posed by artificial intelligence–generated deepfake content. The petition was filed by Sudhir Chaudhary, Journalist and Editor-in-Chief of DD News, seeking judicial intervention against the circulation of misleading and AI-generated videos that falsely attributed statements and opinions to him. The case was heard by Justice Manmeet Pritam Singh Arora, who emphasized the need to preserve an individual’s right to identity, reputation, and privacy in the digital space. The Court’s interim injunction granted Chaudhary protection over the unauthorized use of his name, likeness, image, and voice. It directed Google LLC and other defendant social media entities to remove the infringing content within 48 hours of receiving the order, setting a strong precedent for safeguarding digital personality rights.

Arguments:

The petitioner, represented by Senior Advocate Rajshekhar Rao along with Advocate Rudrali Patil, argued that the proliferation of AI-generated videos on platforms such as YouTube and other social media sites was not only defamatory but also misleading to the public. Rao submitted that these videos depicted Chaudhary making statements he never made and spreading misinformation in his name. He contended that such fabricated content gravely infringed upon the petitioner’s personality rights—his name, image, voice, and reputation—all of which are protected under Article 21 of the Constitution of India. The counsel emphasized that the right to control one’s identity is an intrinsic part of the right to life and personal liberty, and that this right extends to digital spaces. He pointed out that deepfake technology, though innovative, has become a weapon for misinformation, and its unregulated use must be curtailed through judicial oversight. Rao further argued that the platforms hosting such content are bound by due diligence obligations under the Information Technology Act, 2000, and the Intermediary Guidelines and Digital Media Ethics Code Rules, 2021. Therefore, once notified of defamatory or misleading content, they are duty-bound to take it down promptly. The petitioner’s counsel requested an interim injunction to restrain the defendants and all related parties from using Chaudhary’s identity in any form without authorization.

Rao also submitted that additional infringing links had been identified and would be filed before the court by October 20 along with Chaudhary’s affidavit. He requested that the interim injunction be extended to these upcoming links as well, given that they were part of the same pattern of defamation. The counsel urged the court to direct Google LLC and Meta Platforms to cooperate in identifying the individuals behind the dissemination of the deepfake videos, since many of them operated under pseudonymous or anonymous social media accounts. Rao concluded that the damage caused by such deepfake content was irreparable, not only harming Chaudhary’s professional integrity but also eroding public trust in journalism.

The respondents, including social media intermediaries like Google LLC and Meta Platforms, did not actively contest the petition but maintained that they would comply with lawful directions issued by the Court. However, representatives of some smaller social media accounts, identified as defendants 3 to 15, argued that the injunction should not extend beyond specific URLs mentioned in the plaint, as a blanket order could unjustly restrict legitimate expression. They claimed that the petitioner had not proven the authenticity of the alleged AI-generated content and that a thorough forensic verification should precede any takedown directive. The respondents also contended that the platforms function as intermediaries and cannot be held liable for user-generated content until specific notification is received as per the “actual knowledge” standard under Section 79 of the IT Act. Moreover, they cautioned that granting overbroad injunctions could set a precedent for curbing free speech on digital platforms.

Judgement:

After hearing both sides, Justice Manmeet Pritam Singh Arora passed a reasoned interim order protecting the petitioner’s personality rights. The Court observed that in the age of artificial intelligence, the line between authentic and fabricated content has blurred dangerously, requiring proactive judicial protection of individual identity. Justice Arora stated, “Injunction granted, we will give it for name, image, likeness, and voice of Sudhir Chaudhary.” This categorical direction extended the injunction to all forms of misuse, including AI-generated imitations that simulate a person’s speech, appearance, or expressions. The Court ordered that Google LLC and other defendant entities must take down the infringing content within 48 hours of receiving the order, emphasizing that if the original uploader or the intermediary failed to comply, Google LLC itself would be obligated to remove the content.

The Court further directed that Chaudhary should serve copies of the order to all the defendants and to Google LLC, and in the event of non-compliance, the petitioner could directly approach Google for takedown. Additionally, the Court called upon the defendants to provide Basic Subscriber Information (BSI) within three weeks, enabling identification of the anonymous or pseudonymous users responsible for uploading the infringing content. The order also clarified that while summons were issued to the defendants involved in content creation and distribution, Meta and Google were not issued summons as they were not contesting the matter and were expected to cooperate with the takedown directions.

Justice Arora also permitted Chaudhary to inform Google LLC and Meta Platforms about any future content that was identical or substantially similar to the videos challenged in the present suit, and directed that such content be taken down within 48 hours upon notification. This direction effectively extended the injunction’s protective shield to future violations, acknowledging the fast-paced nature of digital dissemination. The Court also allowed Chaudhary to file an amended memo of parties after receiving the subscriber information of those defendants whose identities were still unknown.

In her observations, Justice Arora referred to recent precedents where coordinate benches of the Delhi High Court had granted similar protection to public figures including Sri Sri Ravi Shankar, actor Nagarjuna, Aishwarya Rai Bachchan, Abhishek Bachchan, and producer Karan Johar. These orders collectively demonstrate a growing judicial recognition of “personality rights” as a distinct and enforceable category of rights in Indian law. The Court noted that personality rights are an extension of the right to privacy, dignity, and reputation, all of which are protected under Article 21 of the Constitution. In the digital context, these rights ensure that a person’s identity—whether through name, image, or likeness—cannot be commercially exploited or maliciously misused without consent.

The Court also acknowledged that deepfake technology poses unprecedented challenges to reputation management and media authenticity. It observed that journalists, public figures, and ordinary citizens alike are vulnerable to reputational harm from AI-generated videos that distort reality. Justice Arora emphasized the need for balancing two crucial rights—freedom of expression under Article 19(1)(a) and the right to reputation under Article 21. She underscored that while free speech is fundamental, it cannot extend to deliberate misinformation or impersonation, particularly when it damages an individual’s professional credibility. The Court reaffirmed that intermediaries like Google and Meta bear a responsibility to act promptly upon notification of unlawful or defamatory content, failing which they lose the protection available under Section 79 of the IT Act.

This order marks another milestone in India’s evolving legal response to deepfakes, AI misuse, and personality rights violations. By granting an interim injunction, the Court signaled that the law must adapt to the challenges of technology while preserving fundamental human dignity. The judgment reinforces that identity—both digital and real—remains a personal asset protected by law, and unauthorized replication or distortion of the same is impermissible. The decision also empowers public figures and citizens to seek immediate judicial recourse when faced with AI-generated defamation, ensuring accountability in an era where misinformation can spread globally within minutes.