Bombay High Court Restrains Unauthorised Use Of Actor Samantha Prabhu's Persona, Orders Takedowns

The Bombay High Court has recently granted actor Samantha Ruth Prabhu ad-interim protection against AI-generated deepfakes, morphed and pornographic content, chatbots impersonating her and unauthorised merchandise using her name and likeness.

Justice Madhav J. Jamdar passed the order on October 1, finding a “very strong prima facie case” for restraining the unauthorised use of Prabhu's persona and directing the removal or disabling of access to the infringing content.

Prabhu and her team discovered what the order describes as widespread, organised and systematic misuse of her persona around the third week of July 2026. The material included AI-generated deepfake videos, manipulated and morphed photographs, chatbot personas, unauthorised merchandise and pornographic and obscene content falsely depicting her.

The court recorded that one chatbot persona operated under the obscene username “@pinkpussy69”. It used Prabhu's name, image and persona without authorisation and engaged users in vulgar and sexually suggestive conversations.

Certain online retail websites and a “soundboard” website were also allegedly using Prabhu's name, photographs and likeness to market and sell goods and voice clips.

The court held that the material had been created and disseminated without Prabhu's consent. It observed that its continued dissemination was causing irreparable injury to her goodwill, reputation, dignity and commercial interests.

The court further noted that once such material, particularly pornographic or obscene content, is disseminated online, it can undergo unlimited replication and circulation. Monetary damages alone, it held, would not adequately compensate for the resulting injury.

The court held that Prabhu's personality and publicity rights, as well as her moral rights as a performer, were violated by the creation of the morphed, deepfake and AI-generated material and the unauthorised use of her persona in chatbots and merchandise.

It referred to Article 19(1)(a) of the Constitution, which protects freedom of speech and expression, and Article 21, which protects life and personal liberty, including privacy and the right to live with dignity. Her moral rights as a performer are separately protected under Section 38-B of the Copyright Act, 1957, the court noted.

The court also considered submissions on Rule 3(1)(b) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The order notes that the rule contemplates due diligence by intermediaries.

It also referred to an earlier order in Akshay Kumar's case which had considered the same rule. Prabhu's counsel also relied on orders passed in similar personality-rights cases involving Shruti Haasan and Preity G. Zinta.

The relief granted by the court covers identified infringing content and listings. It also covers further material of a similar nature when Google, Amazon and other platforms are notified in writing by Prabhu or her authorised representative, subject to their right to communicate objections with reasons.

Google and Amazon told the court that they had no objection to implementing the order. They, however, pointed out that some links communicated by Prabhu in future could contain genuine photographs and material.

The court recorded that such objections could be communicated to Prabhu's advocate. If the issue remained unresolved, she would be free to approach the court for appropriate further orders.

The court also gave all parties on the other side liberty to approach it in such a situation. It noted that Rule 3 of the IT Rules contemplates due diligence by an intermediary.

Prabhu's counsel also told the court that the operator of one of the AI chatbots had disabled access to the Botify AI character identified by her after being served with the plaint and interim application.

The parties on the other side have been directed to file affidavits in reply within six weeks. Prabhu may file a rejoinder, if any, within three weeks thereafter.

The matter has been posted to December 10, 2026. The ad-interim relief will continue until further orders.