Case: Arijit Singh v. Codible Ventures LLP & Others (IPR SUIT (L) NO.23443 OF 2024)
Court: Bombay High Court Judge: Justice R. I. Chagla
Year: 26th July 2024
Plaintiff | Defendants |
Arijit Singh | Codible Ventures LLP & Others |
Facts of the Case
Famous playback singer Arijit Singh filed a case in the Bombay High Court against several Artificial Intelligence (AI) platforms, YouTube channels, e-commerce websites, and domain registrars for misusing his voice, name, image, and likeness without permission. The defendants created AI tools and tutorials that allowed users to convert any song or speech into Arijit Singh’s voice using “voice cloning” technology. Some websites also sold t-shirts, mugs, and posters with his pictures, while others used his name to promote events and domain names like arijitsingh.com. Arijit Singh claimed that such unauthorized AI use violated his personality and publicity rights and harmed his reputation and career. He argued that his voice and persona are his intellectual property and cannot be copied for profit. The case became the first major Indian lawsuit addressing AI-generated impersonation and deepfake misuse of a celebrity’s identity.
Procedural History
Arijit Singh filed a commercial intellectual property suit before the Bombay High Court seeking protection of his personality and publicity rights against multiple AI platforms and online entities. Justice R.I. Chagla heard the matter and granted an ex-parte ad-interim injunction, restraining defendants from using or cloning the plaintiff’s voice, name, or image.
Issues Raised
Whether the unauthorized use of Arijit Singh’s voice, image, and likeness by AI platforms amounts to a violation of his personality and publicity rights.
Whether creating and distributing AI-generated voice models and deepfake videos without consent infringes the moral rights of a performer under Section 38B of the Copyright Act, 1957.
Whether AI-based imitation and cloning tools can be legally restrained for misappropriating a celebrity’s identity and reputation.
Whether selling merchandise and domain names bearing the plaintiff’s name and image constitutes commercial exploitation and passing off.
Whether freedom of speech and expression can justify the unauthorized creation or sharing of AI-generated content imitating a celebrity.
Whether the plaintiff is entitled to a dynamic injunction extending to future instances of AI misuse of his personality traits.
Contentions of the Parties
Petitioner’s Arguments
Arijit Singh argued that his voice, image, and likeness form part of his personality and publicity rights, which cannot be used without consent. The AI platforms and YouTube channels had cloned his voice and created deepfake content for profit, causing reputational and economic harm. He contended that such unauthorized use also violated his moral rights as a performer under Section 38B of the Copyright Act, 1957. He emphasized that his identity is his intellectual property, and allowing AI tools to imitate his voice or image would mislead the public and jeopardize his career. He sought an injunction to stop all such misuse.
Respondent’s Arguments
The respondents were AI platform operators, e-commerce sites, and content creators accused of misusing Arijit Singh’s voice and image. Most did not appear at the initial stage, so their defense was limited. However, it was generally claimed that the AI-generated content was meant for educational or entertainment purposes, not commercial exploitation. Some respondents might argue that such AI tools are user-driven and that they only provide technology platforms, not the infringing content themselves. They could also claim freedom of expression under Article 19(1)(a) of the Constitution and deny direct involvement in cloning Arijit Singh’s voice or selling unauthorized merchandise.
Judgment / Decision (150 words)
The Bombay High Court, presided over by Justice R.I. Chagla, held that Arijit Singh’s personality traits — including his voice, name, image, likeness, and persona — are legally protectable. The Court observed that creating or distributing AI-generated voice models or deepfake videos imitating the plaintiff without consent violates his personality and publicity rights. It ruled that making AI tools capable of cloning a celebrity’s voice amounts to unauthorized appropriation and misuse of identity. The Court granted an ex-parte ad-interim injunction, restraining all defendants from using or promoting any AI model, video, or merchandise bearing Arijit Singh’s traits. It also ordered domain registrars to suspend fake websites like arijitsingh.com and directed YouTube and e-commerce sites to remove all infringing content. The Court emphasized that freedom of expression cannot justify commercial exploitation of a celebrity’s persona and recognized the need to protect individuals from AI-based misuse.
Ratio Decidendi (Legal Principle)
The Bombay High Court held that a person’s voice, image, likeness, and persona form an integral part of their personality and publicity rights, and any unauthorized use or imitation through Artificial Intelligence (AI) amounts to violation of these rights. The Court affirmed that creating or distributing AI-generated content replicating a celebrity’s identity without consent is illegal and actionable under tort law and copyright law. It further ruled that freedom of expression under Article 19(1)(a) does not protect acts of commercial exploitation or impersonation. AI tools enabling such imitation must be restrained to safeguard an individual’s privacy, reputation, and moral rights.
Obiter Dicta (Observations)
The Court observed that celebrities and performers are increasingly vulnerable to misuse of their identity through AI-generated content, such as deepfakes and voice cloning. Justice R.I. Chagla remarked that the rapid growth of generative AI poses serious risks to privacy, reputation, and livelihood, especially for artists whose voice and image are core to their profession. The Court emphasized that technological innovation must operate within legal and ethical limits, ensuring respect for consent and individuality. It also noted that such misuse can cause economic harm and public deception, highlighting the urgent need for stronger AI regulation in India to prevent abuse.
Precedents Relied Upon (Important Judgments Referred)
Karan Johar (Also known as Rahul Kumar Johar) v. Indian Pride Advisory Pvt. Ltd.
(2024) – Bombay High Court
Recognized personality and publicity rights of celebrities against unauthorized commercial use.
Anil Kapoor v. Simply Life India (2023 SCC Online Del 6914) – Delhi High Court
Held that misuse of a celebrity’s image, name, or voice through AI or deepfakes violates their publicity rights.
Amitabh Bachchan v. Rajat Nagi (2022) 6 HCC (Del) 641 – Delhi High Court
Granted protection of celebrity identity from unauthorized commercial exploitation.
D.M. Entertainment Pvt. Ltd. v. Baby Gift House (2010 SCC Online Del 4790)
Recognized the right of a celebrity over their persona and its commercial use.
R. Rajagopal v. State of Tamil Nadu (Auto Shankar Case) (1994) 6 SCC 632
Established the right to privacy as part of Article 21 and protected individuals from unauthorized publication of personal identity.
Analysis / Comment
The reasoning in this judgment is sound and progressive, as it recognizes the urgent need to protect individuals—especially celebrities—from the misuse of Artificial Intelligence. The Court correctly balanced individual rights and public interest, emphasizing that technological innovation cannot override privacy, consent, and dignity. While the ruling primarily defends personal rights, it does not unduly restrict legitimate technological use, thus maintaining a fair balance. The decision is consistent with earlier precedents like Anil Kapoor v. Simply Life India and Amitabh Bachchan
v. Rajat Nagi, which also upheld celebrity publicity rights. By extending those principles to AI- generated impersonation, the Court filled an important legal gap in the digital era. This judgment will have a major impact on future AI and IP jurisprudence in India, setting a precedent for holding AI platforms accountable and encouraging the development of ethical and lawful AI use in creative industries.
Critical Appraisal / Personal Opinion
This judgment is a milestone in India’s digital law evolution, as it firmly addresses the dangers of AI misuse and protects creative professionals from identity theft. The Court’s approach was fair, practical, and forward-looking, recognizing both technological progress and personal dignity. It rightly emphasized consent and moral rights as non-negotiable. However, India still needs specific AI liability law to clearly define responsibilities of developers and users in preventing future misuse of artificial intelligence.
Conclusion
The case marks a landmark step in protecting personality rights in the age of Artificial Intelligence. It reinforces that no one can use a person’s voice, image, or likeness without consent, even though AI tools. The judgment strengthens privacy, dignity, and moral rights, guiding future AI regulation and digital accountability in India.
Disclaimer
This article is published by CLEAR LAW (clearlaw.online) strictly for educational and informational purposes only. It does not constitute legal advice, legal opinion, or any form of professional counsel, and must not be relied upon as a substitute for consultation with a qualified legal practitioner. Nothing contained herein shall be construed as creating a lawyer-client relationship between the reader and the author, publisher, or CLEAR LAW (clearlaw.online).
All views, interpretations, and conclusions expressed in this article are solely those of the author and represent independent academic analysis. CLEAR LAW (clearlaw.online) does not endorse, verify, or guarantee the accuracy, completeness, or reliability of the content, and expressly disclaims any responsibility for the same.
While reasonable efforts are made to ensure that the information presented is accurate and up to date, no warranties or representations, express or implied, are made regarding its correctness, adequacy, or applicability to any specific factual or legal situation. Laws, regulations, and judicial interpretations are subject to change, and the content may not reflect the most current legal developments.
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Readers are strongly advised to seek independent legal advice from a qualified professional before making any decisions or taking any action based on the contents of this article. Reliance on any information provided in this article is strictly at the reader's own risk.
By accessing and using this article, the reader expressly agrees to the terms of this disclaimer.
specific AI liability law to clearly define responsibilities of developers and users in preventing future misuse of artificial intelligence.
Conclusion
The case marks a landmark step in protecting personality rights in the age of Artificial Intelligence. It reinforces that no one can use a person’s voice, image, or likeness without consent, even though AI tools. The judgment strengthens privacy, dignity, and moral rights, guiding future AI regulation and digital accountability in India.
Disclaimer
This article is published by CLEAR LAW (clearlaw.online) strictly for educational and informational purposes only. It does not constitute legal advice, legal opinion, or any form of professional counsel, and must not be relied upon as a substitute for consultation with a qualified legal practitioner. Nothing contained herein shall be construed as creating a lawyer-client relationship between the reader and the author, publisher, or CLEAR LAW (clearlaw.online).
All views, interpretations, and conclusions expressed in this article are solely those of the author and represent independent academic analysis. CLEAR LAW (clearlaw.online) does not endorse, verify, or guarantee the accuracy, completeness, or reliability of the content, and expressly disclaims any responsibility for the same.
While reasonable efforts are made to ensure that the information presented is accurate and up to date, no warranties or representations, express or implied, are made regarding its correctness, adequacy, or applicability to any specific factual or legal situation. Laws, regulations, and judicial interpretations are subject to change, and the content may not reflect the most current legal developments.
To the fullest extent permitted by applicable law, CLEAR LAW (clearlaw.online), the author, editors, and publisher disclaim all liability for any direct, indirect, incidental, consequential, or special damages arising out of or in connection with the use of, or reliance upon, this article.
Readers are strongly advised to seek independent legal advice from a qualified professional before making any decisions or taking any action based on the contents of this article. Reliance on any information provided in this article is strictly at the reader's own risk.
By accessing and using this article, the reader expressly agrees to the terms of this disclaimer.
specific AI liability law to clearly define responsibilities of developers and users in preventing future misuse of artificial intelligence.
Conclusion
The case marks a landmark step in protecting personality rights in the age of Artificial Intelligence. It reinforces that no one can use a person’s voice, image, or likeness without consent, even though AI tools. The judgment strengthens privacy, dignity, and moral rights, guiding future AI regulation and digital accountability in India.
Disclaimer
This article is published by CLEAR LAW (clearlaw.online) strictly for educational and informational purposes only. It does not constitute legal advice, legal opinion, or any form of professional counsel, and must not be relied upon as a substitute for consultation with a qualified legal practitioner. Nothing contained herein shall be construed as creating a lawyer-client relationship between the reader and the author, publisher, or CLEAR LAW (clearlaw.online).
All views, interpretations, and conclusions expressed in this article are solely those of the author and represent independent academic analysis. CLEAR LAW (clearlaw.online) does not endorse, verify, or guarantee the accuracy, completeness, or reliability of the content, and expressly disclaims any responsibility for the same.
While reasonable efforts are made to ensure that the information presented is accurate and up to date, no warranties or representations, express or implied, are made regarding its correctness, adequacy, or applicability to any specific factual or legal situation. Laws, regulations, and judicial interpretations are subject to change, and the content may not reflect the most current legal developments.
To the fullest extent permitted by applicable law, CLEAR LAW (clearlaw.online), the author, editors, and publisher disclaim all liability for any direct, indirect, incidental, consequential, or special damages arising out of or in connection with the use of, or reliance upon, this article.
Readers are strongly advised to seek independent legal advice from a qualified professional before making any decisions or taking any action based on the contents of this article. Reliance on any information provided in this article is strictly at the reader's own risk.
By accessing and using this article, the reader expressly agrees to the terms of this disclaimer.