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7. Dr. Saraf then drew the Court's attention to the specific instances that necessitated the filing of the present Suit, which are detailed in paragraphs 46 to 55 of the plaint and in Exhibits "F", "G", and "H" annexed thereto. It is submitted that the infringing activities are set out in the plaint in the following categories of misuse and unlawful exploitation:

(i) The creation and dissemination of AI-generated deepfake videos and morphed images,
(ii) Unauthorized voice cloning and impersonation,

9. Dr. Saraf then proceeded to point out details of the various infringing activities that necessitated the filing of the present Suit, as more particularly set out in paragraphs 46 to 55 and in Exhibits "F", "G", and "H" of the plaint, and which are essentially summarized as follows:

a) Unauthorized creation and dissemination of AI deepfakes/morphed photos/videos:
(i) As pleaded in paragraphs 46.3 to 46.7 of the plaint, Defendant No. 1 (John Doe), operating on Defendant No. 4's platform, YouTube, published/uploaded a purported trailer video titled " Maharshi Valmiki - Teaser Trailer | Akshay Kumar as VALMIKI | Paresh Kiran Kawre 6 27 / 907-IA(L)-33184-2025 (OS).DOC Rawal | Pankaj Tripathi | 2025 ". This AI-generated video depicts the Plaintiff in the role of Maharishi Valmiki by superimposing his likeness, along with those of other actors, onto dramatic scenes without his knowledge, involvement, or consent. It is submitted that the said video went viral in or around September 2025, gaining widespread circulation across multiple media outlets. The deceptively realistic nature of the video misled the public into believing it was genuine and had originated from the Plaintiff, resulting in severe public criticism and reputational harm to the Plaintiff.

(vii) Dr. Saraf further referred to a deepfake/morphed video mentioned in paragraph 48.3 of the plaint, wherein the Plaintiff is falsely depicted as promoting a betting and gambling application. The said video is accessible at the following link:

https://x.com/Jessely35br/status/1752681354083569876? ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm %5E1752681354083569876%7Ctwgr %5E6495708cbc3c46bd43a58abfd8b152461da02394%7Ctwcon %5Es1_&ref_url=https%3A%2F%2Fnewschecker.in%2Ffact-check %2Fdeepfake-ad-of-akshay-kumar-promoting-mobile-game-app- goes-viral. With respect to the said video, Dr. Saraf submits that what is particularly alarming is the deceptively realistic nature of the video, wherein the lip synchronization is remarkably accurate and indistinguishable from genuine footage.

18. Having perused the material on record, I must note that what is truly alarming in a number of these cases is the realistic nature of deepfake images/videos that are being created by using AI. Both in the context of images and videos, the morphing is so sophisticated and deceptive that it is virtually impossible to discern that the same are not genuine images/videos of the Plaintiff. The deepfake video of the Plaintiff making communally inflammatory statements and statements about Rishi Valmiki is deeply concerning. The consequences that can arise from such content being disseminated are indeed most grave and serious. Apart from violating and affecting the Plaintiff's personality and moral rights, such videos also pose a grave threat to the safety and well-being of the Plaintiff's family members and can also have an adverse and widespread impact on society and public order, which clearly appears to be the agenda of those who create such content. Hence, such content needs to be removed from the public domain immediately, not only in the interest of the Plaintiff but also in the larger public interest.