Data Privacy, AI And Technology Newsletter | November 2025

Welcome to the November edition of the Data Privacy, AI and Technology Newsletter. This issue provides a consolidated overview of key industry updates from across India's dynamic technology, telecommunications, and fintech sectors. It highlights notable regulatory and market developments shaping the country's digital ecosystem, including emerging trends in tech innovation, sector-specific compliance changes, and policy shifts impacting service providers and consumers alike. The newsletter also brings you recent judicial pronouncements from the High Courts, offering insights into evolving interpretations of technology and industry-related legal issues.

Updates: Industry Updates: India

Technology Updates

The Ministry of Electronics and Information Technology has notified the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2025:

October 22, 2025: The Ministry of Electronics and Information Technology (MeitY) has notified Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2025 (Rules) introducing additional safeguards to ensure that removal of unlawful content by intermediaries is undertaken in a transparent, proportionate and accountable manner. The Rules came into effect from November 15, 2025. Following are the key features of the Rules:

1. Senior level authorization for removal of unlawful information: Any intimation to intermediaries for removal of unlawful information can now only be issued by a senior officer not below the rank of Joint Secretary, or equivalent, or, where such rank is not appointed, a Director or an officer equivalent in rank- and, where so authorized, acting through a single corresponding officer in its authorized agency, where such agency is so appointed. In case of police authorities, only an officer not below the rank of Deputy Inspector General of Police (DIG), specially authorized, can issue such intimation.
2. Periodic review of all intimations: all intimations issued for removal of unlawful information, will be subject to a monthly review by an officer not below the rank of Secretary of the Appropriate Government to ensure due compliance, proportionality and adherence to statutory requirements.
3. Reasoned intimation along with specific details: The intimation must clearly specify the legal basis and statutory provision, the nature of the unlawful act, and the specific URL/identifier or other electronic location of the information, data or communication link to be removed. This replaces the earlier broad reference to 'notifications' with 'reasoned intimation' to align the Rules with the requirement of 'actual knowledge' as mandated under the IT Act, bringing clarity and precision.

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MeitY proposes draft amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 relating to synthetically generated information:

October 22, 2025: Recognizing the increasing risks associated with the proliferation of synthetically generated information, including deepfakes, misinformation, and other unlawful content, the Ministry of Electronics and Information Technology (MeitY) has proposed draft amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (IT Rules, 2021), and has invited feedback/comments of stakeholders on the draft amendments by November 6, 2025 which was later extended to November 13, 2025. Following are the key highlights of the draft amendments:

1. Introduction of the definition of 'synthetically generated information': which "means information which is artificially or algorithmically created, generated, modified or altered using a computer resource, in a manner that such information reasonably appears to be authentic or true".
2. Protection for removal of harmful synthetic content: provides statutory protection to intermediaries removing or disabling access to synthetically generated information based on reasonable efforts or user grievances, ensuring that such actions do not affect the safe-harbour exemption provided under Section 79(2) of the Information Technology Act, 2000, which exempts intermediaries from liability in respect of any third party information, data or communication link hosted on their platform.
3. Due diligence in relation to synthetically generated information: an intermediary which offers a computer resource that enables, permits, or facilitates the creation, generation, modification or alteration of information as synthetically generated information, must ensure that such information is prominently labelled or embedded with a permanent unique metadata or identifier in a manner that it (a) covers at least ten percent (10%) of surface area of the visual display or (b) in the event of audio content, during the initial ten percent (10%) of its duration, and can be used to immediately identify that such information is synthetically generated information which has been created, generated, modified or altered using the computer resource of the intermediary. Herein the intermediary must ensure that such label is unable to be modified, suppressed or removed.
4. Enhanced obligations for significant social media intermediary (SSMIs): SSMIs such as Google (for YouTube), Facebook (for Facebook, Instagram), LinkedIn, WhatsApp, Telegram etc. are required to mandate users to declare whether such information is synthetically generated information and deploy reasonable technical measures in order to verify the accuracy of such declaration. Furthermore, SSMIs must ensure that the said declaration must be clearly and prominently displayed with an appropriate label or notice, indicating that the content is synthetically generated.

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NITI Aayog released a pioneering study on 'AI for Inclusive Societal Development':

October 8, 2025: NITI Aayog has released a comprehensive and first-of-its-kind study titled 'AI for Inclusive Societal Development' (Study) which explores how AI and frontier technologies can be leveraged to transform the lives and livelihoods of India's 490 million informal workers. The Study has been undertaken in order to align with the Viksit Bharat 2047 vision, which envisions India's transformation into a US$30 trillion economy, a US$18,226 per capita income. The Study emphasizes that AI in isolation, cannot automatically uplift the informal sector. It highlights that structural constraints such as financial insecurity, limited market access, lack of skilling and inadequate social protection cannot be dismantled without deliberate human intervention, focused investments and an enabling ecosystem. To address this gap, in the Study, NITI Aayog has proposed the "Mission Digital ShramSetu", a national mission to create a roadmap and ecosystem that will make AI accessible, affordable and impactful for every worker. The mission seeks to leverage AI, immersive learning tools and other frontier technologies, supported by research and development, data-driven insights, strategic partnerships, and dedicated policy development teams. It aims to empower informal workers by equipping them with innovative tools and digital platforms that enhance their skills, improve productivity and uphold dignity in work.

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Competition Commission of India releases 'Market Study Report on Artificial Intelligence and Competition' conducted through Management Development Institute Society:

October 6, 2025: The Competition Commission of India (CCI) has released a 'Market Study Report on Artificial Intelligence and Competition' (Report), conducted through the Management Development Institute Society (MDIS). The Report highlights that the adoption of AI in India is rapidly accelerating across multiple user sectors, and is reshaping competition dynamics, business operations and regulatory response. While advent of AI offers substantial benefits in efficiency, innovation and consumer experience, there are emerging issues that may directly or indirectly have a bearing on competition and may hinder realization of its full potential. In order to promote the development of a competitive AI ecosystem in India, prevent AI driven anti-competitive practices and protect consumer welfare, the Report proposes measures which inter alia includes:

1. Self- audit: Due to the autonomous and dynamic nature of AI systems, the Report emphasizes the need for robust self-audit framework in order to ensure that AI systems do not inadvertently violate competition law principles. Self-audit framework includes: (a) design and testing of algorithms with built-in safeguards to prevent/ detect unintended anti-competitive outcomes/practices and reduce unfair competition risk; (b) review of AI driven pricing strategies to detect unintended price alignments or discriminatory practices; (c) incorporation of safeguards that prevent sharing of commercially sensitive data among competitors.
2. Increased transparency: Enterprises are encouraged to adopt transparency measures to reduce information asymmetry, by articulating the purpose of deployment of AI in decision-making process; communicating key parameters influencing AI-driven decisions to stakeholders.
3. Removing entry barriers: the stakeholders have suggested that the government departments must focus on expanding national AI computing infrastructure with enhanced access mechanisms; development of data repositories in order provide high quality, nonpersonal datasets.

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MeitY issued the draft Promotion and Regulation of Online Gaming Rules, 2025 and issued a notice inviting stakeholder feedback:

October 2, 2025: The Ministry of Electronics and Information Technology (MeitY) has released the Draft Promotion and Regulation of Online Gaming Rules, 2025 (Draft Rules), inviting public consultation until October 31, 2025. The Draft Rules provides a uniform national framework for structured growth of the online gaming sector through legitimate formats of e-sports and online social games, while prohibiting exploitative and harmful online money games. Outlines below are, inter alia, key provisions proposed:

1. Establishment of Online Gaming Authority of India (Authority): The Draft Rules propose the creation of dedicated Authority, functioning as a digital office responsible for: (i) determining, recognizing and registration of online games; (ii) maintenance and publishing a National Online Social Games and E-sports Registry containing details of all registered online social games and e-sports as deemed necessary; (iii) issuing directions, orders to persons offering, organizing any online game, advertisements relating to online game and financial transactions or authorization of funds towards payment for any online gaming; (iv) issuing guidelines or codes of practice in relation to offering online social games and e-sports.
2. Recognition and registration of online social games and e-sports: An application shall be made to the Authority by an online service provider for registering an online game as either an online social game or an e-sports offering. The application must include the details as deemed necessary for the purposes of registering the game such as- name and contact details of the applicant; name and detailed description of the online game intended to be registered; age group to whom the online game is intended to be offered, etc. The rules also provide the timeline i.e., ninety (90) days within which such application shall be registered by the Authority.
3. Determination of online money games: The Draft Rules set out clear parameters in order to determine whether an online game is an online money game or otherwise, following are the parameters provided:\
   • whether the online game involves any element of money, including payment of fees, deposits or other stakes, or in-game purchases which is in the nature of a stake or wager;
   • whether user participation is contingent upon making a prior deposit of money or other stakes;
   • whether the online game offers winnings, rewards, or payouts in the form of money or other enrichment, which is redeemable, convertible to or can be encashed as money, at any stage in the online game.

If an online game is determined as an online money game, the Authority is empowered to cease its operation and prohibit any advertising, promotion, or facilitation relating to such game.

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Financial Intelligence Unit has issued notices for non-compliance of the Prevention of Money Laundering Act to offshore virtual digital asset service providers:

October 1, 2025: Financial Intelligence Unit India (FIU IND) has issued notices for non-compliance to 25 offshore Virtual Digital Assets Service Providers (VDA SPs) under Section 13 of the Prevention of Money Laundering Act, 2002 (PMLA), which inter alia includes:

• Huione
• BC.game
• Changelly
• Coinex

Pursuant to the notification issued in March 2023, VDA SPs have been brought within the purview of the Anti-Money Laundering and Counter-Financing of Terrorism (AML-CFT) framework under the provisions of the PMLA. Accordingly, all entities carrying out activities in relation to virtual digital assets in India are mandated to register with FIU-IND as reporting entities.

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Telecommunication Updates

Telecom Regulatory Authority of India responded to Department of Telecommunications on recommendations on 'Introduction of Calling Name Presentation (CNAP) service' in India.

October 28, 2025: Telecom Regulatory Authority of India (TRAI) released an official response to Department of Telecommunications (DoT's) back reference relating to the introduction of Calling Name Presentation (CNAP) service in the Indian Telecommunication network. CNAP is a supplementary service that will display the registered name of the caller on the recipient's phone screen.

TRAI vide its previous recommendations had suggested introduction of CNAP as a 'supplementary service' for telephone subscribers who could avail such supplementary services on request. DoT's stance has been that CNAP service should be available by default with the option to cancel upon request.

Having taken note of the responses received from DoT, TRAI has nevertheless reiterated its earlier recommendation, concluding that CNAP to be a supplementary service.

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DoT notified the Telecommunications (Telecom Cyber Security) Amendment Rules, 2025.

October 22, 2025: The Department of Telecommunications (DoT), notified the Telecommunications (Telecom Cyber Security) Amendment Rules, 2025, to amend the Telecommunications (Telecom Cyber Security) Rules, 2024. Key amendments include, inter alia, the following:

• Insertion of a new rule which empowers the Central Government to establish a Mobile Number Validation (MNV) platform for ensuring telecom cybersecurity and preventing security incidents. Entities eligible to submit validation requests upon payment of prescribed fees include: (a) Telecommunication Identifier User Entity (TIUE); (b) the Central Government, State Government, or (c) any authorized agency by them.
• A new provision was added which empowers the Central Government to direct Telecom equipment manufacturers not to assign International Mobile Equipment Identity (IMEI) numbers that already in use within Indian telecommunication networks to newly manufactured or imported equipment. Anyone selling/ buying used telecom equipment with an IMEI number in India will first need to check the government-maintained database for conflicts.

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TRAI convened the 9th Joint Committee of Regulators on issues of spam and cyber fraud.

October 16, 2025: Telecom Regulatory Authority of India (TRAI) held the 9th Meeting of the Joint Committee of Regulators (JCoR) at TRAI headquarters in New Delhi. The meeting was attended by representatives, including the Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI), Pension Fund Regulatory and Development Authority (PFRDA), and the Ministry of Electronics and Information Technology (MeitY), among others. The JCoR committee reviewed the progress of the pilot project for 'Digital Consent Acquisition', being implemented at 11 nominated banks, and focused on regulatory and technical actions to improve consumer protection and enhance the integrity of the digital communication ecosystem. Key outcomes of the meeting, inter alia, include:

1. Agreement of the committee on completion of the pilot of 'Digital Consent Acquisition' by February 2026.
2. Discussions by members relating to the need for mandatory whitelisting of all URLs, OTT links, APKs, and callback numbers used in commercial communication.
3. Discussions that TRAI and Telecom Service Providers (TSPs) may consider publishing the list of entities blacklisted for spamming activities on their respective websites.

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TRAI released draft Telecommunication Tariff (Seventy Second Amendment) Order, 2025 for stakeholder comments:

October 16, 2025: Telecom Regulatory Authority of India (TRAI) issued the Draft Telecommunication Tariff (Seventy Second Amendment) Order, 2025, to modify the Telecommunication Tariff Order, 1999.Stakeholders were requested to furnish their written comments by October 31, 2025, which was later extended till November 7, 2025. The key amendments in the draft order, inter alia, are as follows:

• The service providers failing to meet the reporting requirements will be liable to pay, by way of financial disincentive, an amount of INR 10,000 for each day of delay within the first seven days. If the violation continues beyond seven days, an additional INR 20,000 will be charged for each subsequent day, with a cap of INR 5,00,000. This is a sharp increase from the previous penalty of INR 5,000 per day of delay, with a cap of INR 5,00,000. A reasonable opportunity to represent against the contravention of the tariff order will also be provided to the service provider; and
• In case a service providers fail to pay the amount of financial disincentive within the prescribed period, they shall be liable to pay interest on the outstanding amount of financial disincentive at a prescribed rate.

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TRAI released the draft Reporting System on Accounting Separation (Amendment) Regulations, 2025 for stakeholder comments:

October 16, 2025: Telecom Regulatory Authority of India (TRAI) issued the draft Reporting System on Accounting Separation (Amendment) Regulations, 2025, to modify the Reporting System on Accounting Separation Regulations, 2016. Stakeholders were requested to furnish their written comments by October 31, 2025, which was later extended till November 7, 2025. The key amendments in the draft notification, inter alia, are as follows:

• If a service provider does not submit the required reports, it will be liable to a financial disincentive of INR 20,000 per day for the first seven days, and INR 40,000 per day thereafter, capped at INR 10,00,000. For continued non-compliance in consecutive years, the disincentive will be INR 50,000 per day for the first seven days, and INR 75,000 per day thereafter, capped at INR 25,00,000.

In the earlier framework, if a service provider failed to submit the required reports by the due date, it could be fined up to INR 5,00,000, with an additional penalty of up to INR 50,000 per day for delays beyond 15 days. For consecutive-year defaults, the penalty could go up to INR 10,00,000 per contravention, plus an additional INR 1,00,000 per day for delays beyond 15 days.

• If a service provider submits a false report or knowingly omits a material fact, they may be required to pay a financial disincentive of up to 1% of their turnover. In the earlier framework, this disincentive was up to INR 10,00,000.
• If a service provider does not pay the financial disincentive within the specified time, they will be required to pay additional interest on the outstanding amount as prescribed.

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DoT released the draft Telecommunications (Authorisation for Telecommunication Network) Rules, 2025:

October 09, 2025: Department of Telecommunications (DoT), released the Draft Telecommunications (Authorisation for Telecommunication Network) Rules, 2025, for public consultation till November 9, 2025. Key highlights of the draft rules, inter alia, are as follows:

• Integration of Infrastructure Provider Category-1 (IP-1) registration into the authorization framework and introduction of a new category, the Digital Connectivity Infrastructure Provider (DCIP). Both IP-1 and DCIP authorizations are exempt from authorization fee requirements.
• Introduction of a dedicated Internet Exchange Point (IXP) authorization, which resolved longstanding licensing ambiguity.
• Introduction of a new Cloud-Hosted Telecom Network (CTN) provider authorization, integrating virtualized telecom network functions (software, virtual routers, scalable network topologies) into the telecom regulatory framework.
• Introduction of Satellite Earth Station Gateway (SESG) provider and Mobile Number Portability (MNP) provider authorisations.

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Fintech updates

Reserve Bank of India released guidelines to facilitate faster cross-border inward payments.

October 29, 2025: The Reserve Bank of India (RBI) released the guidelines to make cross-border inward payments cheaper, faster, more transparent, and more accessible. These key guidelines to banks, inter alia, are as follows:

• Banks must notify customers of cross-border inward transactions immediately upon receipt. Messages received after banking hours are to be communicated at the start of the next business day.
• Many banks depend on end-of-day nostro account statements for reconciling receipts, which causes delays. To improve this, banks must reconcile and confirm credits in near real-time or at intervals no longer than thirty minutes.
• Banks must aim to credit inward payments received during foreign exchange market hours to the beneficiary's account within the same business day. Payments received after market hours should be credited on the next business day, ensuring compliance with Foreign Exchange Management Act, 1999 (FEMA) and other regulatory requirements.

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NPCI introduced 'UPI HELP' - a pilot with AI-powered support for UPI payments.

October 8, 2025: National Payments Corporation of India (NPCI) introduced the 'UPI HELP' assistant to enhance user engagement by providing conversational support. NPCI directed all member banks and payment service providers to provide an accessible link to the assistant on official channels and also offer grievance redressal. Key features of the assistant, inter alia, are as follows:

• Digital payment queries: UPI HELP will answer user queries relating to digital payments.
• UPI grievance redressal: Enables users to check the status of their transactions or log and track complaints for service-related issues. UPI HELP will share relevant information with issuer banks to help in faster dispute resolution.
• UPI transaction mandate management: UPI users will be able to see all their active mandates, including 'AutoPays'. The assistant will facilitate easier management of mandates.

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Department of Financial Services launched Initiatives to simplify the digital payment experience at the Global Fintech Festival 2025.

October 7, 2025: The Secretary of the Department of Financial Services, Ministry of Finance, announced the launch of three new digital feature offerings at the Global Fintech Festival (GFF) 2025, which are as follows:

• UPI with On-Device Biometric Authentication: This user-friendly alternative feature allows customers to verify UPI payments directly through their smartphone's built-in security options, such as fingerprint or face unlock, instead of manually entering the UPI PIN.
• Aadhaar-based face authentication in UPI: This feature provides users with a new and secure way to set or reset their UPI PIN directly within UPI apps, making onboarding faster, simpler, and more inclusive.
• Cash withdrawal via micro-ATMs using UPI at UPI cash points (business correspondent touchpoints): This feature enhances inclusivity and ease of use by utilizing UPI's flexible digital payment ecosystem.

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Judgements:

High Court

Madras High Court recognized cryptocurrency as property that can be held in trust.

October 25, 2025: In Rhutikumari v. Zanmai Labs Pvt. Ltd. and Ors. (O.A. No.194 / 2025), the Madras High Court (MHC) recognized cryptocurrency as property capable of being enjoyed, possessed (in a beneficial form), and held in trust.

Facts of the case: The applicant filed the original application under Section 9 of the Arbitration and Conciliation Act, 1996, seeking the grant of an order of injunction restraining the respondents from interfering with the applicant's account/portfolio holding of 3,532.30 XRP cryptocurrency coins on the WazirX platform. The value of coins, as on January 1, 2025, was INR 9,55,148.20.

On July 18, 2024, the respondents made an announcement stating that one of their cold wallets had been subjected to a cyberattack. They subsequently froze the applicant's crypto account and portfolio, preventing her from accessing, trading, or liquidating her XRP coins. The respondents argued that the platform neither takes custody of nor facilitates the transfer of fiat currency funds; such transfers occur solely between users, with no responsibility or liability on the part of the platform. There were two primary issues:

1. Whether the application is maintainable before the MHC, given that the agreement between the parties specified Singapore as the seat of arbitration, and the digital wallets were maintained outside India by a foreign entity.
2. Whether the applicant must be construed as an investor or a proprietor of her holdings, i.e., 3,532.20 XRP coins.

Judgement: The MHC noted that the WazirX platform was operated through the applicant's mobile phone from her ordinary place of residence and, prima facie, held that the asset/cryptocurrency was held by her in India, so the application filed under Section 9 of the Arbitration and Conciliation Act, 1996, is maintainable before MHC.

The court also held that cryptocurrency is treated as a virtual digital asset, rather than a speculative transaction, and therefore constitutes 'property' and subsequently directed the first respondent to furnish a bank guarantee for a sum of INR 9,56,000 in favour of the applicant or deposit the sum in an escrow till the arbitration proceedings come to an end.

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Madras High Court held that Aadhaar card holder has the fundamental right to seek alteration of their details in the Aadhaar card:

October 17, 2025: In P. Pushpam Vs. the Director, Unique Identification Authority of India and Another (W.P(MD)No.29394 of 2025), the Madras High Court held that the right to receive the benefits is a fundamental right and Aadhaar Card is a mandatory vehicle through which the benefit can be received, the card holder has the concomitant fundamental right to seek alteration of the demographic information in the card as per Section 31 of Aadhaar (Targeted Delivery of Financial and Other Subsidies Benefits and Services) Act, 2016.

Facts of the case: A writ petition was filed by a senior citizen, recently widowed, whose late husband had served in the Indian Army and was a recipient of an army pension. Upon his demise, the petitioner sought transfer of the said pension account in her name. However, the petitioner's request could not be processed owing to discrepancies identified in her Aadhaar Card, specifically pertaining to her name and date of birth, which resulted in procedural impediments in effectuating the pension transfer.

Judgment: Madras High Court observed that the Aadhaar Card has become an indispensable identity document, the absence of which may result in the denial of several benefits and services. Consequently, the accuracy of the information contained therein is of paramount importance, and the responsibility to ensure such correctness rests upon the Aadhaar number holder, while the authority is correspondingly obligated to facilitate necessary corrections. The court further noted that while certain modifications such as changes to address or phone number can be effected at the local level, alterations pertaining to name, date of birth, or biometric information can only be carried out at the Aadhaar Seva Kendra, Madurai, due to infrastructural limitations.

The court held that the alteration of information in the Aadhaar Card constitutes a statutory function performed by the authority and that every Aadhaar number holder possesses a fundamental right to avail the services provided under the Aadhaar regime. Accordingly, it is the statutory duty of the authority to ensure the establishment of adequate infrastructure and to make all facilities accessible, thereby enabling individuals to exercise their rights without undue hardship. In view of the foregoing, the Court directed the authority to carry out the requisite alterations in the petitioner's Aadhaar Card.

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Bombay High Court grants protection to Akshay Kumar's personality rights:

October 15, 2025: In Akshay Hari Om Bhatia Vs. John Doe and Others (Interim Application (L) No. 33184 of 2025), the Bombay High Court granted ex parte ad interim relief in favour of the plaintiff, Mr. Akshay Kumar (Plaintiff), thereby protecting his personality rights. The court recognized the Plaintiff's exclusive proprietary and commercial right in the use of his (a) the name, including screen name and any abbreviation, moniker, or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance, and mannerisms; and (f) signature and any other uniquely identifiable attribute, and directed several unknown entities and social media platforms and also websites to take down/remove/disable access to all listings/pages/content, which exploit/misuse Plaintiff's personality rights.

Facts of the case: It has been submitted by the Plaintiff that there has been misuse and unlawful exploitation of his personality rights through (a) creation and dissemination of AI-generated deepfake videos and morphed images, (b) unauthorized voice cloning and impersonation, (c) sale of merchandise bearing the plaintiff's likeness, and (d) other unlawful uses. It is further submitted that a recent deepfake video, falsely portraying the Plaintiff as making communally inflammatory remarks and statements concerning Rishi Valmiki, has gone viral across social media platforms. Attention has been drawn to the grave implications of such fabrications, particularly given the high degree of realism of these AI-generated depictions, which pose a serious threat to the Plaintiff's reputation, dignity, and public image, as well as to the safety and well-being of his family members.

Judgement: The court expressed concern over the "realistic" nature of deepfake images and videos generated by using AI. It observed that in both images and videos, the degree of morphing is so sophisticated and deceptive that it is virtually impossible to discern that the same are not genuine images/videos of the Plaintiff. Furthermore, the court also recognized the grave and irreparable harm that such deepfake video poses to the Plaintiff and his family. Accordingly, the court granted an ex parte interim relief in favour of the Plaintiff, restraining the unknown entities and social media platforms and also websites from utilizing, misappropriating, exploiting, imitating, selling, offering, or dealing in any goods or services, including counterfeit merchandise, by using any of the Plaintiff's protected personality attributes, namely (i) the name including plaintiff's screen name and any abbreviation, moniker or variation thereof; (ii) voice; (iii) image; (iv) likeness; (v) distinctive performance, appearance and mannerisms; and (vi) signature and any other uniquely identifiable attribute on any medium and in any manner whatsoever. The court further directed the concerned entities, websites and platforms to take down, remove, and/or disable access to all listings, pages, and content identified as infringing or violative of the Plaintiff's personality and publicity rights.

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Bombay High Court grants protection to Suniel Shetty against AI-generated deepfakes and false endorsements:

October 10, 2025: In Suniel V Shetty Vs. John Doe S Ashok Kumar (Commercial IP Suit (L) No. 32130 of 2025), the Bombay High Court granted an ex parte ad interim relief to the Indian actor Suniel Shetty (Plaintiff) over unauthorized use of his persona through AI generated deepfakes, impersonation and false endorsements online. The court observed that unauthorized creation/uploading of deepfake images and videos of the Plaintiff on social media platforms constitutes a grave infringement to not only of his personality rights but also constitutes a blatant invasion of privacy and his is right to live with dignity under Article 21 of the Constitution. The Court also noted that such conduct impacts not only the Plaintiff but extends to his family members, thereby aggravating the degree of harm and warranting immediate injunctive relief.

Facts of the case: The Plaintiff, a well-recognized actor with a significant degree of public recognition and a substantial digital presence, submitted that multiple online entities have engaged in the systematic and unauthorized exploitation of his personality, image, and reputation, through (a) the creation and circulation of AI-generated images and deepfakes, some depicting him and his family in obscene or defamatory ways; (b) false endorsements associating him with gambling websites, astrology and numerology services, and real estate promotions; (c) the sale of counterfeit merchandise bearing his name and likeness; and (d) the creation of impersonating social media accounts, misleading the public.

Judgement: The court granted an ex parte interim relief, prohibiting any further use of Plaintiff's personality rights and/or moral rights namely: (a) the name "Suniel Shetty" and any abbreviation, moniker or variation thereof; (b) voice; (c) image; (d) likeness; (e) distinctive performance, appearance and mannerisms; and (f) signature and any other uniquely identifiable attribute. The court also directed social media platforms to take down/remove/disable access to all listings/pages/content identified as infringing content within one (1) week from the date of the receipt of this order. Furthermore, these platforms have been directed that, upon subsequent request by the Plaintiff about similar misuse, subject to any restrictions, shall disclose details such as usernames, addresses, email ID, contact number, IP logs, registration details and payment details of the individuals responsible, to enable the Plaintiff to implead them before the court.

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