Personality Rights in the Generative AI Era: 2025 Delhi High Court Trends
The explosive growth of generative AI has created new legal problems associated with commercial misuse of various aspects of an individual’s identity. During 2025, the Delhi High Court became the first court to deal with such problems by issuing several ex parte interim injunctions under “John Doe proceedings.” This essay will examine some of the relevant orders of 2025 to highlight how the Indian judiciary responded innovatively by extending personality rights, which are grounded in Articles 21 and common law notions of publicity and passing off, to address the threat of deepfakes, voice cloning, artificial voice production, and AI chatbot misuse. Although all these decisions clearly establish that there is a sufficient prima facie case for personality rights based on dignity and goodwill, there are certain contradictions between privacy-based consent approaches and traditional IPR jurisprudence that need to be addressed.
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