Contributed by: Priya Dutt; Reviewed by Adv. Manvee<\/em><\/p>\n The Bombay High Court\u2019s ex parte ad interim order in Arijit Singh v. Codible Ventures LLP and Ors.<\/em> is a significant decision on personality rights, publicity rights, AI voice cloning, deepfakes, and unauthorized commercial use of a celebrity\u2019s identity in India. This case analysis explains the facts, issues, reasoning, interim relief, and practical implications for artists, AI platforms, creators, and brands in India.<\/p>\n Arijit\u2019s case represents a significant development in India\u2019s evolving <\/a>personality rights jurisprudence, particularly adapted to confront the advanced challenges of generative artificial intelligence, voice cloning, and deepfake synthesis. Arijit Singh, a renowned playback singer and personality, is a global icon whose legal struggle represents a seminal case for the legal protection of an artist\u2019s digital personality in a world where technology is often in a race with current legislation.<\/p>\n The nature of the dispute in Arijit Singh v. Codible Ventures<\/em> is the unlicensed commercial exploitation of the plaintiff\u2019s most intimate and distinctive personality traits in the form of his voice, vocal style, mannerisms, and performance persona. The defendants in this case are AI platform owners and creators of artificial media who have used sophisticated algorithms to reproduce the plaintiff\u2019s distinctive personality traits without his permission or license and have essentially commercialised the plaintiff\u2019s identity for their own financial gain.\u00a0\u00a0<\/p>\n It is particularly noteworthy that Arijit\u2019s case marks the first instance in Indian law dealing specifically with the misappropriation of generative AI technology in relation to the violation of personality rights. It challenges the status quo in intellectual property and rights law by arguing that a person\u2019s persona, especially a unique voice, is a form of intellectual property that cannot be exploited by technological ingenuity. The case represents a clash between technological ingenuity and a person\u2019s inherent right to control the commercial use of one\u2019s identity, which is increasingly being accepted as a significant aspect of a person\u2019s dignity and economic value.\u00a0\u00a0<\/p>\n The case involved 38 defendants, including AI platform operators, e-commerce sellers, domain name registrars, cloud\/data storage platforms, and unknown \u201cJohn Doe\/Ashok Kumar\u201d defendants. The Plaintiff (inter alia \u201cArijit Singh\u201d) alleged that these defendants misused his personality traits, including his name, voice, vocal style, image, likeness, signature, and persona, without authorization. The order records allegations that certain AI platforms enabled users to convert speech, text, or audio into an AI-generated version of Arijit Singh\u2019s voice, including through Real Voice Cloning technology, and that a dataset of 456 songs from the Plaintiff\u2019s repertoire had been uploaded without authorisation for voice-conversion purposes. The Plaintiff also alleged that the founder of Defendant No. 2 promoted tutorials showing users how to clone Singh\u2019s voice using the relevant AI platform.<\/p>\n The Plaintiff alleged the following forms of unauthorized use:<\/p>\n Beyond AI voice cloning, the Plaintiff alleged broader commercial exploitation of his publicity rights through false association, unauthorised merchandise, GIFs, and domain-name misuse. The Plaintiff\u2019s case was that these activities were not isolated fan uses, but a pattern of unauthorised exploitation of goodwill and celebrity identity that could affect his reputation, endorsement value, and livelihood as a professional singer.<\/p>\n The Bombay High Court considered whether unauthorized use of a celebrity\u2019s name, voice, likeness, persona, image, signature, and singing style can amount to a violation of personality rights and publicity rights.<\/p>\n The key legal issues were:<\/strong><\/p>\n The legal arguments for Arijit Singh were based on the school of thought that an individual\u2019s identity is an asset that has been cultivated with the hard work and dedication of several years. The plaintiff argued that an individual has an absolute right to command and control the commercial use of his personality traits since they are the primary identifiers of the individual\u2019s brand and source of livelihood.\u00a0<\/p>\n The plaintiff argued that the use of voice cloning is an extremely invasive form of technological exploitation. The defendant\u2019s use of AI technology and training it with a dataset of 456 unauthorised songs was not merely replicating the sounds but was essentially \u201cpirating\u201d the essence of Singh\u2019s professional identity. The plaintiff argued that this violated the exclusive right of an individual to commercially exploit his personality and also amounted to the tort of dilution by tarnishment.<\/p>\n Moreover, it was contended that \u201cunauthorized transformation or synthesis of the plaintiff\u2019s voice creates deep prejudice and injury to the plaintiff\u2019s professional honor and thus violates the statutory moral rights of the plaintiff as a performer under Section 38-B of the Copyright Act.\u201d<\/em> The plaintiff\u2019s counsel also highlighted his \u201cconscious personal choice\u201d<\/em> of not engaging in gross commercialization and brand endorsements for several years and thus the forced engagement by the defendant had an even more damaging impact on the plaintiff\u2019s reputation. \u00a0<\/strong><\/p>\n Because the order was passed ex parte, the defendants did not substantively present their defences at this stage. Any discussion of fair use, transformative use, parody, education, safe harbour, or the absence of a dedicated AI statute should therefore be presented as potential issues for later adjudication, not as actual defendant submissions in this order.<\/p>\n Justice R.I. Chagla\u2019s reasoning focused on three points: first, celebrity personality attributes are protectable against unauthorised commercial exploitation; second, AI tools that enable conversion of a person\u2019s voice into a celebrity\u2019s voice can facilitate appropriation of a key identity marker; and third, urgent ex parte relief was justified because online and AI-enabled misuse can spread quickly and cause irreparable harm.<\/p>\n The court started by holding that celebrities have a right to a high degree of protection for their \u201cpersonality rights,\u201d which include name, image, likeness, voice, and signatures. This right is based upon a \u201cright to privacy.\u201d The Supreme Court of India has held that this right is a fundamental right under Article 21 in Puttaswamy vs Union of India.\u00a0 The Court reached a prima facie view at the ad-interim stage and relied on existing celebrity-rights precedents, including Karan Johar, Anil Kapoor, Amitabh Bachchan, D.M. Entertainment, and Rajagopal as discussed in the order.<\/p>\n The rationale for this decision is that a person\u2019s identity is not just a matter of personal information but is a form of economic interest that a person has a right to control and that allowing others to use a celebrity\u2019s identity would be tantamount to allowing others to \u201cride upon\u201d a celebrity\u2019s hard-earned fame and success. The court noted that fame subjects a person to a variety of vulnerabilities, such as the theft of a celebrity\u2019s endorsement value, which is a significant source of living.\u00a0\u00a0<\/p>\n An important aspect of the reasoning was the court\u2019s careful consideration of the \u201cprotectable facets\u201d of Singh\u2019s personality. The judgment also determined that the voice of a professional singer is as \u201cdistinctive and personal as a face\u201d.\u00a0<\/p>\n The court argued that the imitation of a singer\u2019s voice by AI synthesis amounts to \u201cAI voice cloning may amount to unauthorised appropriation of identity\u201d. This is because the singer manifests herself in her song, and the tool that imitates her voice without her permission takes away her ability to control her own identity.<\/p>\n Justice Chagla\u2019s profound \u201cshock to the conscience\u201d was directed towards the targeting of performers by generative AI content. The court noted how AI platforms were \u201cleveraging\u201d Arijit Singh\u2019s popularity to attract traffic and \u201cembolden\u201d users to create \u201ccounterfeit\u201d recordings.\u00a0<\/p>\n The Court was particularly concerned that AI-generated voice and video content could be misused for commercial, deceptive, or nefarious purposes. It also clarified that freedom of speech may protect critique and commentary, but does not permit commercial exploitation of a celebrity\u2019s persona without consent.<\/p>\n In arriving at its decision to grant ad-interim relief, the court had to apply the threefold test that is usually applicable while granting injunctions: the prima facie case, balance of convenience, and irreparable injury. The court found that the documents filed were sufficient to prove that Singh was a celebrity and that the misuses by the defendants were for pecuniary gain.<\/p>\n The balance of convenience was clearly in favor of the plaintiff, as the stakes were high, not only for his career but also because, in the age of instantaneous dissemination of content, monetary damages would not have been sufficient. This called for a flexible injunction that could reflect the fluidity of the internet space and mirror sites.\u00a0<\/p>\n The Bombay High Court granted an ex parte ad-interim injunction. For accuracy, do not call this a final decision or final judgment. The order restrained unauthorised use of Singh\u2019s personality attributes and directed takedown, domain-locking\/suspension, disclosure, and access-disabling measures against the relevant defendants and intermediaries.<\/p>\n The operative part of the order contained the following directions:\u00a0\u00a0\u00a0<\/strong><\/p>\n 1. Restraint on Persona Use:<\/strong> The defendants, as well as all the associated entities, were restrained from using Arijit\u2019s name, voice, picture, image, caricature, or signature for any commercial or personal benefit without his express consent.<\/p>\n 2. AI Prohibitions:<\/strong> The court specifically prohibited the development or use of AI voice models, synthetic voice, avatar, as well as deepfakes that simulate, mimic, or replicate Arijit\u2019s personality traits.<\/p>\n 3. Content Takedown and Domain Suspension:<\/strong> The defendants were ordered to take down the infringing content, including tutorial videos as well as song covers. The Domain Name Registrars (DNRs) were ordered to lock and suspend the infringing domain names, such as arijitsingh.com, with a prohibition on the transfer of the domain names to third parties.<\/p>\n 4. Regulatory Interventions:<\/strong> The Department of Telecommunications (DoT), as well as the Ministry of Electronics and Information Technology (MeitY) were ordered to direct all Internet Service Providers (ISPs) to disable access to the particular infringing URLs.<\/p>\n 5. Disclosure Mandates<\/strong>: E-commerce as well as cloud storage service providers, including Amazon, Flipkart, and Google, were ordered to disclose all the details of the defendants involved in the unauthorised sale of merchandise.<\/p>\n The court emphasised that while freedom of speech permits \u201ccritique and commentary,\u201d it does not grant a license to exploit a celebrity\u2019s persona for commercial profit.\u00a0\u00a0\u00a0<\/p>\n The Arijit Singh<\/em> judgment has distilled several core principles that serve as the bedrock for the future of digital identity law in India :\u00a0\u00a0\u00a0<\/p>\n The order is an important development, but the analysis should remain measured. It strengthens personality-rights protection against AI-enabled misuse, while also exposing unresolved questions on statutory codification, intermediary liability, fan works, parody, training data, and non-celebrity voice protection.<\/p>\n The order broadens the practical understanding of likeness and persona by including voice, vocal style, and mannerisms. However, avoid inventing labels such as \u2018commercial gestalt\u2019 unless you define them as commentary. The more defensible analysis is that Indian courts are moving toward consent-based control over commercially valuable identity attributes.<\/p>\n India still lacks a single dedicated statute on personality rights or AI voice cloning. Claimants currently rely on a combination of personality\/publicity rights, privacy principles, passing off, copyright\/performance rights, tort principles, and injunctive relief. This patchwork creates uncertainty, especially for non-celebrities and for lawful commentary, parody, and fan expression. This has resulted in a lack of consistency and has led to the application of different tests by different High Courts. For example, the test applied by the Delhi High Court is the \u201cLikelihood of Confusion\u201d test, while the test applied by the Bombay High Court is the \u201cCommercial Identification\u201d test.<\/p>\n The intervention of the court in editing specific content in YouTube videos instead of a blanket ban on channels shows a high degree of understanding and awareness about balancing rights. However, the continued availability of cloned content on some platforms in spite of this order shows that courts move at a \u201cglacial\u201d pace in contrast to the \u201cinstantaneous\u201d pace of cybercrimes and cyberlaws.<\/p>\n AI voice-cloning and text-to-speech platforms should treat this order as a compliance warning. Practical controls include consent checks for celebrity voice models, notice-and-takedown workflows, repeat-infringer controls, dataset provenance review and filters for protected names and voices.<\/p>\n Generative AI platforms should adopt transparency-by-design, including clear AI-generated labels, provenance metadata where feasible, and user-facing restrictions on cloning identifiable voices without consent. The Arijit Singh<\/em> case underscores that fair use\/free speech arguments are weaker where the use is commercial, misleading or identity-exploitative.<\/p>\n For influencers and creators, the case signals that distinctive identity features \u2013 including voice, image, catchphrases, delivery style, and performance persona \u2013 may have legal and commercial value. Not every meme, parody, critique, or fan edit will automatically be unlawful; context, purpose, identifiability, and commercial use matter.<\/p>\n For startups and platforms, the practical legal takeaway is to build a consent-and-risk framework before launching voice-cloning, avatar, deepfake, or celebrity-style AI features. Key controls include:<\/p>\n The judicial reasoning in India mirrors foundational cases from the United States. In Midler v. Ford Motor Co.<\/em> (1988), the 9th Circuit established that \u201cWe hold only that when a distinctive voice of a professional singer is widely known and is deliberately imitated in order to sell a product, the sellers have appropriated what is not theirs and have committed a tort in California\u201d.[1]<\/a> Similarly, in Waits v. Frito-Lay, Inc.<\/em> (1992), the court protected Tom Waits\u2019 raspy voice against a deliberate sound-alike imitation used for a commercial, awarding him $2.6 million in damages.\u00a0\u00a0The Ninth Circuit Appellate Court found that when voice is a sufficient indicator of a celebrity\u2019s identity, the right of publicity protects against its imitation for commercial purposes without the celebrity\u2019s consent. This right is protected in California understate tort law. Under the federal Lanham Act, celebrity singers have standing to sue for voice misappropriation because of the likelihood that wrongful use of their professional trademark-their voices-would injure them commercially.[2]<\/a><\/p>\n Unlike the US cases, which focused on human mimics, the Arijit Singh<\/em> case addresses the massive scalability of AI replication, which can generate thousands of unauthorised performances in seconds.\u00a0\u00a0\u00a0<\/p>\n Jurisdictions are increasingly recognising voice and likeness as protectable identity attributes, particularly in response to AI-generated impersonation. Tennessee\u2019s ELVIS Act<\/em> (2024) specifically adds \u201cvoice\u201d as a protectable attribute to its publicity statutes, aimed directly at AI companies.\u00a0The Act defines \u201cvoice\u201d to include \u201ca sound in a medium that is readily identifiable and attributable to a particular individual, regardless of whether the sound contains the actual voice or a simulation of the voice of the individual.\u201d This broad definition raises the spectre that liability under the ELVIS Act may extend not only to the use of an existing sound recording of someone\u2019s voice, and not only to digitally generated recordings or audiovisual content that approximates individual voices, but also to humans who can imitate other artists (i.e., soundalike artists).[3]<\/a><\/p>\n The obligations for disclosing synthetic content, including deepfakes, primarily fall under Article 52 (transparency requirements for general-purpose AI models) and related Title III provisions for high-risk systems. While Article 5 prohibits certain manipulative AI practices, it does not specifically target deepfakes; violations can incur fines up to 7% of global turnover under Article 101.\u00a0<\/p>\nIntroduction<\/strong><\/h2>\n
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<\/figure>\nQuick Summary of the Arijit Singh AI Voice Cloning Case<\/strong><\/h2>\n
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Facts of the Case<\/strong><\/h2>\n
Key Allegations Before the Bombay High Court<\/strong><\/h2>\n
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Legal Issues in Arijit Singh v. Codible Ventures<\/strong><\/h2>\n
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Arguments by the Parties<\/strong><\/h2>\n
Plaintiff\u2019s Contentions<\/strong><\/h3>\n
Potential Defences\/Issues Not Fully Tested at the Ex Parte Stage<\/strong>
Court\u2019s Reasoning<\/strong><\/h2>\n
(a) Recognition of Personality Rights<\/strong><\/h3>\n
(b) Voice and Likeness as Protectable Attributes<\/strong><\/h3>\n
(c) Digital Misappropriation and Technology<\/strong><\/h3>\n
(d) Need for Injunctive Relief<\/strong><\/h3>\n
Order and Relief Granted<\/strong><\/h2>\n
Key Legal Principles from this Case<\/strong><\/h2>\n
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Critical Analysis<\/strong><\/h2>\n
Expansion of Personality Rights Jurisprudence<\/strong><\/h2>\n
Lack of a Statutory Framework<\/strong><\/h2>\n
Judicial Approach to Emerging Technologies<\/strong><\/h2>\n
How the Arijit Singh Case Shapes AI Voice Cloning and Deepfake Regulation<\/strong><\/h2>\n
(a) Impact on AI Voice Cloning Tools<\/strong><\/h3>\n
(b) Relevance for Generative AI Platforms<\/strong><\/h3>\n
(c) Implications for Influencer & Creator Economy<\/strong><\/h3>\n
(d) Lessons for Tech Startups and Platforms<\/strong><\/h3>\n
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Comparison with Global Deepfake and Voice Rights Cases<\/strong><\/h2>\n
US Precedents: Bette Midler and Tom Waits<\/strong><\/h3>\n
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\n \nCase Element<\/td>\n Arijit Singh (India, 2024)<\/td>\n Midler & Waits (US, 1988\/92)<\/td>\n<\/tr>\n<\/thead>\n \n Identifier<\/strong><\/td>\n Voice Timbre, Style, Mannerisms.<\/td>\n Distinctive Singing Voice.<\/td>\n<\/tr>\n \n Infringement<\/strong><\/td>\n Algorithmic Generative AI Synthesis.<\/td>\n Human \u201cSound-Alike\u201d Impersonators.<\/td>\n<\/tr>\n \n Legal Ground<\/strong><\/td>\n Article 21 Privacy & Moral Rights.<\/td>\n Common Law Right of Publicity.<\/td>\n<\/tr>\n \n Remedy<\/strong><\/td>\n Dynamic & Ex-parte Injunctions.<\/td>\n Punitive & Compensatory Damages.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/figure>\n Statutory Trends: Tennessee ELVIS Act and EU AI Act<\/strong><\/h2>\n