Protection of Personality Rights in India in the Era of AI in Comparison to the United States, European Union, and United Kingdom: Understanding the Contrast

At the intersection of copyright, personality rights, and the right to publicity, the proliferation of deep fakes, i.e., synthetic media, AI-generated media, cheap fakes/shallow fakes, and digital forgery has created complex legal challenges. Unauthorized digital impersonations of prominent figures, officials, and celebrities have increased disputes across South Asian jurisdictions, particularly India. The digital revolution has fundamentally altered how celebrity identity is commodified, exploited, and protected. Recent litigation in Indian courts concerning unauthorized use of celebrity personas, particularly through artificial intelligence and deepfake mechanisms, reflects this shift. The Delhi High Court has recently acted to safeguard Bollywood personalities, including Aishwarya Rai Bachchan, Abhishek Bachchan, and filmmaker Karan Johar, from unauthorized commercial exploitation. These developments mark a turning point in India's celebrity personality rights jurisprudence. This paper undertakes a doctrinal analysis of Indian and South Asian statutory frameworks and judicial precedents, with comparative perspectives from the United States, European Union, and United Kingdom. It advocates statutory recognition of personality rights and clearer copyright rules for AI-generated works while balancing free speech and privacy.