Delhi High Court Protects Tabuâs Personality Rights Orders Removal Of AI-Generated Obscene Content

The Delhi High Court has granted Bollywood actor Tabu an ex-parte interim injunction protecting her personality and publicity rights, in a significant ruling that also addresses the growing misuse of artificial intelligence to manipulate celebrity images and videos.

Justice Jyoti Singh, hearing a petition filed by Tabu, directed several major digital platforms, including Google, Meta, X and Reddit, to remove or disable access to more than 150 identified URLs allegedly carrying unauthorised and objectionable content involving the actor. The order also includes directions to certain platforms and domain service providers to share Basic Subscriber Information and IP log details that could help identify individuals behind the disputed accounts and content.

Tabu had approached the court alleging that her identity and public persona were being exploited online without her consent. Her complaints covered a range of alleged violations, from fake event-booking accounts and unauthorised merchandise to fabricated statements and digitally manipulated content.

The court observed that Tabu's name and stage name, along with her image, voice, likeness and other distinctive attributes, have acquired a unique identity in the public consciousness. It found that the actor had established a prima facie case for interim protection and that she could suffer irreparable harm if the alleged misuse continued.

Court takes note of AI-generated obscene content

One of the more serious allegations concerned AI-generated obscene images, videos and GIFs that allegedly used material taken from Tabu's films, interviews and public appearances.

According to the plaint, portions of movie scenes had allegedly been edited, slowed down or zoomed in to emphasise intimate moments before being circulated online. Tabu's case was that such material was being sensationalised and used to drive traffic and generate revenue.

The court took a particularly serious view of the alleged practice, observing that the dissemination of deliberately manipulated material, including AI-generated videos, could cause irreparable damage to Tabu's goodwill, reputation and commercial value.

The interim order restrains the defendants, including unidentified John Does, from using, exploiting or misappropriating any attribute of Tabu's personality or publicity rights without her consent. The protection extends to her stage name, real name Tabassum Jamal Hashmi, voice recordings and duplications, signatures and initials, photographs, images and movie stills.

Crucially, the order specifically covers misuse through AI, Generative AI, Machine Learning, deepfakes, face morphing and GIFs. The restrictions apply across websites, mobile applications, social media platforms, the Metaverse and other physical or virtual spaces.

The court also referred to previous Delhi High Court decisions recognising personality rights, including D.M. Entertainment v. Baby Gift House, Anil Kapoor v. Simply Life India and Jaikishan Kakubhai Saraf v. Peppy Store. The court noted that unauthorised commercial exploitation of a celebrity's distinctive identity can result not only in commercial loss but also affect privacy, personality and the individual's right to live with dignity.

Another issue before the court was an online publication carrying a statement allegedly attributed to Tabu that she categorically denied making. Despite clarifications reportedly being issued to leading newspapers, the material allegedly remained online. The court described its continued publication as an "egregious act" and directed the concerned publisher to remove the statement from all its platforms within three days of receiving the order.

Google, Meta, X and Reddit directed to take down content

The court has issued detailed directions to some of the world's largest digital platforms. Google has been ordered to remove or disable 21 URLs in one set, eight in another and five in a third, while Meta has been directed to act against 73 URLs in Document-A, 28 in Document-B and five in Document-C. X has been directed to remove three identified URLs, while eBay and Reddit have also been ordered to take down specified material.

The platforms have been given 36 hours from receipt of the order to comply with the relevant directions.

Tabu's petition also raised concerns over an Instagram account allegedly offering bookings for her appearances and performances. The actor claimed she had no connection with the account and had never authorised anyone to arrange bookings on her behalf. The account, which allegedly had around 2,000 followers, was accused of using her name, photographs and videos to create an impression of an association.

The case also covers allegedly unauthorised merchandise featuring Tabu's photographs, including mugs, posters, calendars, hoodies and sweatshirts. Her counsel argued that such products effectively created an unauthorised commercial association with the actor and exploited the value attached to her public persona.

The Delhi High Court's order therefore goes beyond simply asking platforms to remove specific pieces of content. By expressly extending protection to AI-generated material, deepfakes, voice duplication and other emerging technologies, it underlines the growing legal challenge celebrities face in protecting their identities in an increasingly synthetic digital landscape.




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