Introduction
You wake up one Sunday, finally getting the time to relax after a hectic week. You open YouTube on your phone to watch some comedy and wait to skip the advertisement. But within seconds, you are filled with anxiety because you see your face and hear your voice in that advertisement, suddenly endorsing a product you never even heard of. This is what happened to one of India’s most recognised playback singers, and someday the same can happen to you. But before understanding what protections are available to you, it is worth clarifying that the law that protected him was specifically designed for people who are at the same level of fame, and whether the same extends to an ordinary person remains untested.
The Factual Matrix and Claims of Infringement
In 2024, Arijit Singh approached the Bombay High Court upon discovering several unauthorised uses of his persona.[1] He alleged that fake recordings were created that copied his voice using artificial intelligence tools. This was done to use his likeness to falsely suggest that[2]:
- He would perform at or endorse a virtual event,
- Merchandise bearing his name, image, caricature, and likeness was being sold on platforms including Amazon and Flipkart,
- Platforms can allow users to create and share GIFs made from his image and performances, and
- Domain names like “arijitsingh.com” and “arijitsingh.in” have been registered without his consent.
In fact, a defendant had unlawfully uploaded 456 of his songs for training its AI platform.
The Bombay High Court’s Ruling and Interim Relief
The suit, Arijit Singh v. Codible Ventures LLP & Ors., included 38 defendants, including AI platforms, merchandise sellers, domain registrants, owners of e-commerce platforms, and others.[3] On 26th July, 2024, an ex parte ad interim injunction was passed based on the strength and urgency of the harm claimed. The Court recognised that a performer’s career and economic livelihood can be severely harmed through AI cloning of one’s voice. It considered a singer’s voice as a commercial asset built through years of hard work instead of merely a personal characteristic. The decision included:
- Unauthorised use of Singh’s name, voice, vocal style, mannerisms, image, and signature across physical and digital environments was stopped. The technologies responsible for such use included AI-based technologies such as voice cloning, voice conversion, synthesized voice, digital avatars, deepfakes, face morphing, and GIFs.
- The defendants were ordered to remove existing infringing content, suspend the 2 disputed domain names, and delete unauthorized references to Singh’s persona from the videos uploaded on the internet.
The Evolution of Personality and Publicity Rights in India
Personality rights are not codified in any single Indian statute, but rather they have developed through judicial interpretation of the constitutional right to privacy.
The foundational case is R. Rajagopal v. State of Tamil Nadu (1994)[4], commonly referred to as the “Auto Shankar case,” where the Supreme Court ruled that the right to privacy is a part of the right to life and liberty guaranteed by Article 21 of the Constitution. In that case, the right at stake was related to an autobiography of a convict, and not a celebrity endorsement, but it provided the constitutional basis upon which subsequent personality and publicity rights would be built.
Subsequently, Indian courts developed a series of precedents on misuse of a person’s identity for commercial purposes. ICC Development (International) Ltd. v. Arvee Enterprises (2003)[5] decided that publicity rights are connected with privacy rights and that corporate entities are precluded from claiming those rights. Titan Industries Ltd. v. Ramkumar Jewellers (2012) reiterated that a celebrity’s identity has commercial value and cannot be used without his or her consent. Finally, in Shivaji Rao Gaikwad v. Varsha Productions (2015), the court applied that logic to protect actor Rajinikanth’s personality.
The most relevant precedent with regard to the order in question is Anil Kapoor v. Simply Life India (2023)[6]. The Delhi High Court, presided over by Justice Prathibha M. Singh, prohibited unauthorised commercial exploitation of the name, image, voice and trademarked catchphrase “Jhakaas” of film actor Anil Kapoor, on grounds that such unauthorised use would deprive the celebrity of “one of the major sources of income”. In addition, Justice Chagla had already passed an ad-interim injunction on 13 June 2024 in the case of Karan Johar v. India Pride Advisory Pvt. Ltd.,[7] which prevented the use of the filmmaker’s name in the title of a movie (this being prior to, and not subsequent to, the Arijit Singh case). Finally, Amitabh Bachchan v. Rajat Nagi & Ors.[8] provided injunctive relief for the actor against unauthorised commercial exploitation of his voice and image.
The Bombay High Court’s decision in the Arijit Singh case used all of the above legal precedents in the context of synthetic media made possible through AI technologies that can replicate the voice of a real-life individual even without any human performer.
Legal Significance of the case
The Codible Ventures order is often regarded as one of the most important rulings that addressed the issue of misusing a named performer’s persona through a commercial AI voice-cloning platform.[9]
First, it bridges a key statutory gap. Copyright law protects a particular recording but not the recognisable voice identity of a person, whereas personality rights protect this void.
Second, using earlier judgments, this order used a practical framework where:
- the claimant must be identifiable as an individual with an established public reputation
- the defendant’s use must make that individual identifiable
- the use must be for commercial gain
Finally, the order made it evident that AI-based impersonation is considered serious and urgent enough to grant an emergency, ex parte relief.
Applicability to Private Citizens: Alternative Statutory Remedies
Coming back to the central question: if your voice is used to sell insurance someday, would your rights be protected in the same way as Singh’s? The honest answer is no- not entirely similar, and this is where the comparison becomes careful.
The framework built through the above-mentioned precedents has a very important qualifier: the person seeking protection of their personality rights should be someone having significant public goodwill connected to their name or voice.
The Indian judiciary has not considered any such case yet involving an average individual having their voice cloned but without the prior presence of a public reputation to invoke personality rights. The success of such a case is a logical possibility in view of the trends set out by the case laws, but it is not a certainty. It will be subject to how “identifiability” and “commercial gain” may be defined outside the scope of celebrities.
However, that does not mean that there will be no legal recourse for an average individual. There are alternative laws beyond personality rights which can apply to such scenarios:
- identity theft and impersonation laws from Sections 66C and 66D of the Information Technology Act, 2000
- intermediary takedown obligations under the IT Rules 2021
- digital personal data protection laws under the Digital Personal Data Protection Act, 2023
- consumer protection and criminal laws in general.
All these legal avenues have not been explored in a similar fashion as personality rights for any AI voice cloning case yet, and thus the exact ambit is still to be determined.
What Singh’s case proves then is not that “you too now have that right.” What it proves is that courts in India are prepared to move fast and take strong action where the claimant can demonstrate that he has a recognized reputation, that he is identifiable, and that he uses his reputation commercially. That is becoming increasingly easy for a recognized personality to prove. For everybody else, the law in this particular area is still, at best, an undecided issue, and, at worst, a vacuum that will need to be filled by legislation.
[1] ‘Bollywood Singer Prevails in First AI Voice-Cloning Infringement Decision in India – WTR’ <https://www.worldtrademarkreview.com/article/bollywood-singer-prevails-in-first-ai-voice-cloning-infringement-decision-in-india> accessed 15 September 2026.
[2] ibid
[3] Arijit Singh v Codible Ventures and Ors, SCC OnLine Bom 2445, 26 July 2024.
[4] AIR 1995 SC 264
[5] (2003) 26 PTC 245 (Del.)
[6] CS(COMM) 652/2023
[7] 2025 SCC OnLine Bom 546
[8] CS (COMM) 819/2022
[9] ‘AI Voice Cloning: How a Bollywood Veteran Set a Legal Precedent’ <https://www.wipo.int/en/web/wipo-magazine/articles/ai-voice-cloning-how-a-bollywood-veteran-set-a-legal-precedent-73631> accessed 15 September 2026.
