AI, Defamation, and Digital Rights: Delhi High Court Sets a Precedent in the case of Manchu Vishnu Vardhan Babu v. Arebumdum & Ors.

Summary

The present case has been filed by actor and producer, Mr. Manchu Vishnu against several YouTube channels before the Delhi High Court for alleged unauthorized use of his image, voice, and likeness which harmed his personality rights. The Plaintiff submits that the Defendants have used his likeness in AI-manipulated videos which resulted in defamation and harm to his reputation. He said, this is a misutilization of his rights under the Copyright Act, 1957. The Court ordered an interim injunction against the Defendants restraining them from using Vishnu’s persona, and it further directed YouTube to remove all infringing content not voluntarily removed by the Defendants within 48 hours.

Case Timeline

• October 1, 2024: Manchu Vishnu filed a lawsuit seeking an injunction against unauthorized use of his persona.
• Interim Injunction Issued: The Court granted an ex-parte interim injunction, barring the Defendants from using Vishnu’s name, voice, or likeness without his consent.
• Compliance Orders for YouTube: YouTube was instructed to take down infringing content within 48 hours if the Defendants did not comply voluntarily. The platform was also required to provide identifying details for Defendants who had not come forward.
• Next Hearing: Scheduled for January 22, 2025, to monitor compliance with Order XXXIX Rule 3 CPC.

Issues Raised

The issues that the Plaintiff raises in this case include infringement of personality and publicity rights in the unauthorized use of his name, voice, and image to either misled the public or damaged his reputation. The issues add defamation problems where he claims that the AI mixed content humiliated and embarrassed him. Copyright infringement arises through unauthorized use of his performances. Lastly, he claimed that the Defendants commercially exploited him since they were earning money from his persona because of the rise in viewership and affiliate links in the video descriptions, an unfair use of his persona and violative of his rights on personality and publicity.

Plaintiff’s Arguments

Therefore, the Plaintiff accused that his persona, voice, image, or likeness has sufficient commercial value and its unauthorized use for commercial purposes creates confusion and damages his reputation. He insisted that the AI-altered videos portray him in a generally adverse manner and expose him to defamation with damage to his public persona. He then stated that his performance is within the scope of the Copyright Act, under which he has special rights concerning any change or abuse that affects his image. The Plaintiff contended that in the Defendants’ commercial use of his persona without authority, exploitation and infringement of his exclusive right to control his image occurred.

Respondent’s Arguments

The Defendants did not formally respond. Although they might argue that it is fair use, arguing that their material or images are either entertainment or parody under the right to expression, or that the coincidence was completely without their intention towards the similarity of Vishnu. They could attack the Plaintiff’s rights over publicly published images.

Judgement

The Court granted an interim injunction in favor of the Plaintiff, prohibiting the Defendants from using Vishnu’s name, image, voice, or likeness without his consent. YouTube was directed to remove any infringing content within 48 hours of non-compliance by the Defendants. Furthermore, the Court ordered that YouTube provide necessary details of the Defendants who uploaded the infringing content. The next hearing is set for January 2025, to review compliance with the Court’s orders and any responses from the Defendants.

Analysis

This case underlines the shifting legal framework around personality rights and digital identity, especially in an advanced AI-capable world. Manchu Vishnu’s suit against YouTube channels using AI-modified videos of his likeness for unauthorized commercial purposes spotlights the complicated interplay between freedom of expression and the right of an individual to his or her image. The granting of an interim injunction by the Delhi High Court provides ample evidence of the proactive approach of the Delhi High Court towards protecting individuals in general and public figures, in particular, from exploitation and defamation which may come through AI-driven alterations. These efforts are part and parcel of judicial recognition that personality rights are integral aspects of intellectual property and personal dignity, with bearings on the future.

An instruction from the Court to delete infringing content within a reasonable period of time underlined the role of digital platforms in regulating harmful or unauthorized content. It demonstrates a trend toward holding tech companies responsible for user-uploaded content where it infringes on personality rights. The obligation on YouTube to reveal the identities of the Defendants involved further points out the Court’s interest in these rights and the need to curtail possible misuse.

Perhaps this case will act as a precedent to further strengthen the boundaries of digital rights with AI applications, the use of celebrity image, and digital rights. That is to say, content creators and platforms should now realize that there is legal redress against the abuse of someone’s face for commercial purposes without permission. Future decisions by the Courts in dealing with the idioms of technology and what it portends on privacy and identity could thus mean new legislative action or more stringent digital platform policies to protect one’s digital and personality rights.