”Deepfakes And Ai-Generated Non-Consensual Imagery As Technology-Facilitated Sexual Violence: A Doctrinal Analysis Of India’s Legal Response”

Kapil Singhal
Department of law, Vikrant University, Gwalior
Guide: Prof. Dr. Vir Narayan
Professor
School of legal studies
Vikrant University, Gwalior
shahkapil83@gmail.com

Abstract

The proliferation of generative artificial intelligence has given rise to a new and particularly insidious form of technology-facilitated sexual violence against women: the non-consensual creation and circulation of AI-generated sexually explicit or obscene imagery, popularly termed “deepfakes.” Unlike earlier forms of image-based abuse, deepfake sexual content does not require an original intimate photograph; it can be entirely fabricated from a woman’s publicly available, non-intimate images.^[1] This paper undertakes a doctrinal analysis of India’s legal response to this phenomenon, examining the applicability and adequacy of the Information Technology Act, 2000, the Bharatiya Nyaya Sanhita, 2023, the Digital Personal Data Protection Act, 2023, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026, which introduce the regulatory category of “Synthetically Generated Information.” The study also examines the emerging body of High Court jurisprudence through which courts have used personality rights and Article 21 of the Constitution to fill an evident legislative vacuum. The paper argues that while India’s 2026 regulatory intervention represents meaningful progress on platform accountability, the substantive criminal law continues to rely on provisions drafted for physically captured images rather than algorithmically fabricated ones,^[2] and that access to judicial relief remains structurally skewed toward well-resourced, high-visibility litigants.

Keywords: deepfakes, non-consensual intimate imagery, technology-facilitated violence, cyber-crime against women, Information Technology Act, Bharatiya Nyaya Sanhita.

1. INTRODUCTION

The last decade has witnessed the transformation of cyber-crime against women from text-based harassment and unauthorised circulation of genuine intimate photographs to a qualitatively different threat: the algorithmic fabrication of sexually explicit imagery that never existed in reality. Generative adversarial networks and, more recently, consumer-facing AI image and video tools have made it possible to superimpose a woman’s face onto explicit content, or to generate wholly synthetic sexualised depictions of her, within seconds and at negligible cost. A ten-country survey of over 16,000 respondents found that non-consensual synthetic intimate imagery is already a measurable form of victimisation and that existing legislation in countries with specific deepfake laws has not been sufficient to deter perpetration.^[3]

This shift matters for criminology and law for three reasons. First, it decouples the harm from any prior act of image capture the traditional anchor of “voyeurism” and “revenge pornography” offences since the abusive image is created, not stolen or leaked. Second, it dramatically lowers the barrier to perpetration, enabling volume-based, low-accountability abuse against ordinary women and public figures alike. Third, it exposes the extent to which India’s existing legal architecture for cyber-crimes against women built primarily around the Information Technology Act, 2000 and provisions of the erstwhile Indian Penal Code, now reorganised under the Bharatiya Nyaya Sanhita, 2023^[4] was not designed with synthetic, AI-fabricated content in mind.^[5]

India’s legal response has evolved rapidly over the last two years. The Bharatiya Nyaya Sanhita, 2023 came into force on 1 July 2024, retaining and modestly strengthening the erstwhile IPC provisions on voyeurism, stalking, and outraging modesty. More significantly, the Ministry of Electronics and Information Technology notified the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026 on 10 February 2026, introducing for the first time a statutory definition of “Synthetically Generated Information” and imposing rapid takedown and labelling obligations on intermediaries.^[6] Parallelly, constitutional courts have been compelled to develop interim doctrinal responses to deepfake-related privacy violations in the absence of a dedicated substantive offence, most visibly in a string of 2025–2026 orders concerning film personalities.^{[7] [8]}

This paper critically examines whether this composite legal framework part statute, part subordinate legislation, part judge-made doctrine meaningfully protects women against AI-generated non-consensual sexual imagery, or whether it remains a reactive patchwork built on legal categories designed for a pre-generative-AI world.

2. Literature Review

Scholarship on cyber-crimes against women in India has traditionally clustered around three themes: the adequacy of statutory definitions for online sexual harassment and stalking, the procedural and evidentiary difficulties of prosecuting anonymised offenders, and the sociological dimension of underreporting owing to stigma. The most directly relevant doctrinal contribution argues that Indian defamation law and the sexual-harassment provisions of the erstwhile Penal Code were not designed for, and remain poorly suited to, the specific dynamics of image-based victimisation in cyberspace, since these frameworks presuppose either a false statement of fact or physical proximity between offender and victim assumptions that do not map neatly onto the circulation of fabricated images.^[9] That scholarship further proposes a dedicated statutory provision addressing non-consensual image-based victimisation, to be inserted into the Bharatiya Nyaya Sanhita immediately following the stalking provision.

A second strand of literature, situated within victimology and criminology, frames online sexual abuse through the lens of technology-facilitated violence (TFV), which treats digital platforms not merely as a medium for existing offences but as an enabling environment that alters the frequency, scale, and anonymity of victimisation. This literature situates image-based sexual abuse including deepfake pornography, sextortion, and the taking or sharing of sexual assault imagery within a broader causal and consequential framework, arguing that legal and non-legal responses have lagged behind the pace of technological change.^[10]

A third and rapidly growing body of literature responds specifically to generative AI. The largest known multinational study of its kind found that non-consensual synthetic intimate imagery was widely perceived as harmful across all ten countries surveyed, but that awareness of, and confidence in, available legal remedies remained low even where deepfake-specific legislation existed.^[11] A related socio-psychological study adds that judgements of image-based sexual harassment and abuse are shaped by the celebrity status of both perpetrator and victim, with implications for how such cases are perceived and prioritised by the public and by institutions a finding with direct bearing on this paper’s analysis of celebrity-centred litigation in India.^[12]

Indian commentary on the IT Rules, 2026 amendment has similarly noted that the introduction of “Synthetically Generated Information” as a defined regulatory category is a significant first step, but existing analysis has focused primarily on intermediary compliance burdens^[13] rather than on victim-centred criminal law reform, leaving a gap that this paper seeks to address. Finally, journalistic and legal commentary tracking the recent line of Bombay and Delhi High Court orders^[14] has observed that Indian courts are increasingly using personality rights and Article 21 privacy jurisprudence to grant interim relief in the absence of codified deepfake law, a trend that has been both welcomed as pragmatic and questioned as an ad hoc, litigant-resourced substitute for legislative action.

3. Statement Of The Problem

Despite incremental regulatory and judicial responses, India lacks a codified, victim-accessible legal framework specifically addressing the non-consensual creation and circulation of AI-generated sexual imagery of women. Existing provisions under the IT Act and BNS were drafted around the paradigm of a genuine image being captured or shared without consent, not one being algorithmically fabricated.^[15] The relief that has emerged through High Court civil suits invoking personality rights is, on the present evidence, available in practice chiefly to celebrities and public figures with the resources to litigate, raising a doctrinal and equity concern regarding the accessibility of protection for ordinary women.

4. Objectives Of The Study

• To critically examine the adequacy of the Information Technology Act, 2000 and the Bharatiya Nyaya Sanhita, 2023 in addressing AI-generated non-consensual sexual imagery of women.
• To analyse the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026 and its treatment of “Synthetically Generated Information” as a regulatory response to deepfakes.
• To examine the emerging judicial trend of using personality rights and Article 21 privacy jurisprudence to grant relief against deepfake content, and to assess its limitations as a general remedy.
• To identify doctrinal and structural gaps in the existing legal framework from a victimological and technology-facilitated-violence perspective.
• To recommend statutory and institutional reforms for a more accessible and victim-centred legal response.

5. RESEARCH QUESTIONS

• Are the existing provisions of the IT Act, 2000 and the BNS, 2023 doctrinally equipped to address sexual imagery that is fabricated rather than captured?
• Does the IT Rules, 2026 amendment adequately translate platform-level accountability into effective, timely relief for individual victims?
• Is judicial reliance on personality rights and Article 21 an adequate and equitable substitute for a dedicated statutory offence?

6. Hypotheses

H1: India’s existing statutory framework, though nominally applicable through general provisions on voyeurism, obscenity, and impersonation, does not adequately or specifically criminalise the fabrication (as opposed to the capture or circulation) of AI-generated sexual imagery of women.

H2: Judicial relief against deepfake sexual content in India is, in current practice, disproportionately accessible to high-visibility litigants, rendering it an inadequate substitute for a codified, uniformly accessible remedy.

7. Research Methodology

This study adopts a purely doctrinal (black-letter) research methodology appropriate to the discipline of criminology’s legal-analytical tradition. It relies on primary legal sources — the Information Technology Act, 2000; the Bharatiya Nyaya Sanhita, 2023; the Digital Personal Data Protection Act, 2023; the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 as amended in 2026; and reported High Court orders read alongside secondary sources comprising peer-reviewed scholarship^{[16][17][18][19]}, government notifications, and contemporaneous legal commentary. No primary empirical data (survey or interview-based) has been collected; the analysis proceeds through statutory interpretation, case-law analysis, and comparative doctrinal reasoning. The doctrinal method is used here not merely descriptively but critically provisions are tested against the specific factual pattern of AI-fabricated (as distinct from captured) sexual imagery to assess interpretive fit.

8. Conceptual Framework: Technology-Facilitated Sexual Violence

This paper situates deepfake-based sexual abuse within the criminological framework of technology-facilitated violence (TFV), which conceptualises digital platforms as an enabling environment for gendered harm rather than a neutral conduit.^[20] Applying routine activity theory, three elements converge in the deepfake context: a motivated offender enabled by low-cost, low-skill generative tools; a suitable target in any woman with a discoverable digital photograph, irrespective of her public profile; and an absence of capable guardianship, since platform moderation is reactive rather than preventive and law-enforcement capacity for cyber-forensic investigation remains limited. Unlike traditional non-consensual intimate imagery (NCII), which requires the offender to have obtained a genuine intimate photograph, deepfake sexual abuse removes this precondition entirely, expanding the pool of potential victims to include any woman with a public social media presence.^[21] This conceptual distinction is central to the doctrinal critique that follows: statutory provisions premised on the capture or breach of an existing intimate image do not neatly extend to content that was never real.

9. legal framework governing deepfakes and non-consensual imagery in india

9.1 constitutional foundation

The doctrinal starting point for all judicial intervention in this area is the recognition of privacy as a fundamental right under Article 21 of the Constitution, affirmed by the Supreme Court in Justice K.S. Puttaswamy (Retd.) v. Union of India.^[22] Indian courts confronting deepfake sexual content have consistently invoked this foundation, holding that no person and, as the Bombay High Court has specifically emphasised, no woman in particular may be portrayed in a manner that violates her fundamental right to privacy without her knowledge or consent.^[23]

9.2 The Information Technology Act, 2000

Several provisions of the IT Act, 2000 are pressed into service against deepfake content, though none was drafted with synthetic media in mind. Section 66C penalises identity theft through fraudulent use of a person’s identifying features; Section 66D addresses cheating by personation using a computer resource; and Section 66E criminalises the capturing, publishing, or transmission of images of a person’s private area without consent. Sections 67 and 67A penalise the publication or transmission of obscene and sexually explicit material in electronic form respectively.^[24] These criminal provisions are applied directly to deepfake matters despite the interpretive strain of applying “capturing” and “private area” language, framed around a real photographic act, to wholly fabricated synthetic imagery.^[25]

9.3 The Bharatiya Nyaya Sanhita, 2023

The BNS, 2023, in force since 1 July 2024, reorganises and modestly enhances the erstwhile IPC’s sexual offence provisions relevant to women without introducing a distinct deepfake or synthetic-imagery offence. Section 75 addresses sexual harassment; Section 77 criminalises voyeurism watching or capturing the image of a woman engaged in a private act without her consent; Section 78 addresses stalking, extending expressly to monitoring a woman’s use of the internet, email, or electronic communication; and Section 79 penalises acts intended to insult the modesty of a woman.^[26] Section 356 provides the BNS equivalent of criminal defamation, and has been applied, alongside Sections 75 and 77, to deepfake-related complaints.^[27] As with the IT Act, the voyeurism provision under Section 77 is textually anchored to “watching” or “capturing” an image of a woman “engaging in a private act” language premised on a real act being observed or filmed, which sits uneasily with wholly AI-fabricated depictions of acts that never occurred.^[28]

9.4 THE IT (INTERMEDIARY GUIDELINES) AMENDMENT RULES, 2026

The most significant recent development is the notification of the IT Amendment Rules, 2026, which for the first time introduces a statutory definition of “Synthetically Generated Information” (SGI) content that appears reasonably authentic but is artificially or algorithmically generated, modified, or altered using a computer resource.^[29] The amendment classifies non-consensual intimate imagery and sexualised deepfakes as a category of “Prohibited SGI” alongside child sexual exploitation material and impersonation-based fraud, and imposes a compressed takedown timeline of approximately three hours for flagged content pursuant to lawful government or court orders, with a shorter window reported for the most sensitive category involving non-consensual intimate imagery.^[30][31] Platforms enabling the creation or wide dissemination of synthetic content face enhanced due-diligence obligations, and a new Rule 2(1B) provides intermediaries an express safe-harbour carve-out for proactively removing or labelling SGI, resolving a prior disincentive under which voluntary content moderation risked forfeiting Section 79 protection under the IT Act.^[32]

This is a materially significant regulatory intervention: it is the first instance of Indian law explicitly naming and defining synthetic media as a distinct regulatory object, rather than relying on interpretive extension of provisions written for genuine content. However, the amendment operates at the level of intermediary due diligence and platform liability; it does not itself create a new substantive criminal offence tailored to the fabrication of sexual imagery, nor does it establish a direct, victim-initiated compensation or redressal claim outside the ordinary criminal and civil process.

9.5 THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023

The DPDP Act, 2023^[33] is of limited but growing relevance, since a woman’s photograph used as source material for a deepfake constitutes her personal data, and its processing to generate synthetic sexual content without consent implicates the Act’s consent-based processing framework. However, the DPDP Act is oriented toward data-fiduciary obligations and regulatory penalties rather than individual criminal liability for the offender who generates the content, limiting its practical utility as a stand-alone victim-facing remedy.

9.6 The Madras High Court Ncii Standard Operating Procedure

In July 2025, the Madras High Court, hearing a case brought by a woman lawyer whose intimate images had allegedly been circulated without consent, directed the Ministry of Electronics and Information Technology to develop a uniform, victim-centric mechanism for removing non-consensual intimate imagery online.^[34] The resulting Standard Operating Procedure sets out reporting channels, inter-agency coordination, and takedown timelines, and the Court expressly held that online sexual humiliation, image morphing, and extortion-linked circulation of such content constitute a serious intrusion into bodily privacy, dignity, and the Article 21 right to life, rejecting any characterisation of such conduct as a purely private dispute.^[35] This SOP represents a rare instance of an administrative, non-litigious redressal pathway being judicially mandated — though its reach and effectiveness for the general population, as opposed to the specific litigant, remains to be doctrinally tested.

10. judicial trends: analysis of case law

In the near-total absence of a codified deepfake offence, India’s constitutional courts principally the Bombay and Delhi High Courts have developed an increasingly consistent line of interim relief grounded in personality rights and Article 21.

In Shilpa Shetty Kundra v. Getoutlive.in,^[36] the Bombay High Court granted interim protection restraining the circulation of AI-generated deepfake and morphed obscene content bearing the applicant’s likeness, holding that no person, and no woman in particular, may be portrayed in a manner that violates her Article 21 right to privacy without her knowledge or consent, and that such content ought to be deprecated even without entering into the separate question of personality rights under copyright law.^[37]

Shortly thereafter, in proceedings brought by actor Preity Zinta, the Bombay High Court directed major platforms including Meta, Google, and X Corp to remove deepfake videos, morphed photographs, and AI-generated chatbot personas using her likeness without consent, holding that such unauthorised use violated rights protected under Articles 19(1)(a) and 21 of the Constitution. Commentary on the order notes that it builds on a growing line of similar interim reliefs granted to public figures including Akshay Kumar, Suniel Shetty, Kartik Aaryan, Arijit Singh, Amitabh Bachchan, and the late Asha Bhosle, and observes that India still lacks a dedicated statute regulating deepfakes, leaving courts to fill the gap through constitutional and personality-rights reasoning.^[38]

A similar petition by actor Aishwarya Rai Bachchan before the Delhi High Court in which counsel submitted that her likeness was being used to generate sexualised content resulted in the Court orally indicating that an ad-interim injunction was likely to curb further misuse of her identity pending final hearing, following the precedent of earlier personality-rights protections granted to Anil Kapoor and Amitabh Bachchan.^[39]

Separately, in July 2025 the Madras High Court, hearing the complaint of a woman lawyer whose morphed intimate images had been circulated, held that such conduct amounted to a serious intrusion into bodily privacy, decisional dignity, reputation, and the constitutional protection of life under Article 21, and directed the development of the nationwide NCII takedown SOP discussed above a rare instance of relief extending doctrinally beyond a celebrity litigant to an ordinary woman professional.^[40]

Taken together, and consistent with the finding that public judgement of image-based sexual abuse is shaped by the celebrity status of those involved,^[41] this body of jurisprudence demonstrates two things. First, Indian constitutional courts have been doctrinally willing and able to recognise deepfake sexual content as a serious violation of dignity and privacy, using Article 21 and personality rights as flexible, technology-neutral doctrinal tools. Second, and more troublingly for the purposes of this study’s second hypothesis, nearly all reported instances of such relief involve film and entertainment personalities capable of engaging senior counsel and filing civil suits in the original side jurisdiction of a High Court a route that is, as a practical and doctrinal matter, largely unavailable to the ordinary woman victim outside the exceptional Madras High Court matter. This asymmetry supports the concern that judge-made relief, however doctrinally sound, cannot substitute for a codified and uniformly accessible statutory remedy.

11. findings

• India has no dedicated statutory offence criminalising the fabrication of AI-generated non-consensual sexual imagery; existing reliance on IT Act Sections 66C, 66D, 66E, 67, 67A and BNS Sections 75, 77, 78, 79, and 356 involves interpretive extension of provisions drafted around the capture or circulation of genuine images, not algorithmic fabrication.
• The IT (Intermediary Guidelines) Amendment Rules, 2026 mark a substantial regulatory advance by formally defining “Synthetically Generated Information” and imposing rapid takedown and labelling obligations, but this framework operates principally at the level of intermediary due diligence rather than creating a direct, victim-accessible criminal remedy or compensation mechanism.
• Rule 2(1B)’s safe-harbour carve-out for proactive content moderation is a positive structural fix to a pre-existing disincentive, but it protects platforms rather than compensating or empowering victims.
• Judicial relief through personality rights and Article 21 has proven doctrinally robust but is, on the presently available evidence, concentrated among high-visibility litigants with the resources to file civil suits in High Courts; the Madras High Court’s NCII-SOP direction is a notable, and currently isolated, exception extending relief to a non-celebrity victim.
• The DPDP Act, 2023 offers indirect, consent-framework-based leverage but is not structured as a victim-facing criminal or compensatory remedy.
• There remains no nationally uniform, statutorily backed, low-cost administrative redressal mechanism comparable to the Madras High Court’s SOP that an ordinary woman victim, without recourse to High Court litigation, can invoke as a matter of right.

12. conclusion

This study set out to critically examine the adequacy of India’s legal response to AI-generated non-consensual sexual imagery of women. The doctrinal analysis substantiates both hypotheses advanced at the outset. First, India’s substantive criminal law spread across the IT Act, 2000 and the BNS, 2023 remains conceptually tethered to the paradigm of a genuine image being captured, obtained, or shared without consent, and its application to wholly fabricated synthetic content, while judicially and prosecutorially attempted, rests on interpretive extension rather than deliberate statutory design. Second, and more structurally, the principal source of actual relief presently available to victims civil suits invoking personality rights and Article 21 privacy jurisprudence before High Courts has in practice been accessed overwhelmingly by film and entertainment personalities, raising a genuine equity concern about the accessibility of protection for the ordinary woman without comparable resources or public visibility. The IT Amendment Rules, 2026 represent a genuinely significant regulatory step forward, being the first instance of Indian law formally naming and defining synthetic media as a distinct object of regulation, and the Madras High Court’s direction for a nationwide NCII Standard Operating Procedure signals a promising, if still nascent, movement toward accessible administrative redressal. Nonetheless, the overall legal architecture remains reactive, fragmented across at least four instruments, and insufficiently anchored in a dedicated, victim-centred criminal offence targeting the fabrication and not merely the capture or circulation of non-consensual sexual imagery.

13. Recommendations

• Enact a dedicated statutory provision, whether by amendment to the Bharatiya Nyaya Sanhita or as a standalone offence, that specifically criminalises the non-consensual creation, possession, and circulation of AI-generated or digitally fabricated sexual imagery, using fabrication-neutral language that does not presuppose an underlying genuine photograph, along lines consistent with the provision proposed by Halder and Basu.^[42]
• Extend the Madras High Court’s NCII Standard Operating Procedure into a statutorily backed, nationally uniform administrative takedown and redressal mechanism, accessible directly through the National Cyber Crime Reporting Portal without requiring civil litigation before a High Court.
• Introduce a statutory victim compensation scheme for technology-facilitated sexual abuse, recognising that criminal prosecution of anonymous or extraterritorial offenders is frequently unsuccessful and that civil injunctive relief alone does not redress harm already suffered.
• Mandate proactive detection obligations and not merely reactive takedown upon notice for platforms enabling generative AI image and video creation, calibrated against the enhanced due-diligence categories already introduced under the IT Amendment Rules, 2026.
• Establish specialised cyber-crime fast-track courts or designated benches with cyber-forensic expertise at the trial court level, reducing dependence on High Court original-side civil jurisdiction as the primary effective venue for urgent relief.

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[1]Rebecca Umbach and others, ‘Non-Consensual Synthetic Intimate Imagery: Prevalence, Attitudes, and Knowledge in 10 Countries’ (2024) Proceedings of the 2024 CHI Conference on Human Factors in Computing Systems, Article 779, accessed 26 August 2026.

[2]Debarati Halder and Subhajit Basu, ‘Digital Dichotomies: Navigating Non-Consensual Image-Based Harassment and Legal Challenges in India’ (2024) 34(2) Information & Communications Technology Law, accessed 26 August 2026.

[3]Umbach and others (n 1).

[4]Bharatiya Nyaya Sanhita 2023, ss 75, 77, 78, 79, 356.

[5]Halder and Basu (n 2).

[6]Mondaq, ‘IT Rules 2026 Deepfake Regulation: Three Hour Takedowns And AI Labelling Obligations’ (Mondaq India, 18 March 2026), accessed 26 August 2026.

[7]Verdictum, ‘Personality Rights Are Shield For Women Against Privacy Violations: Bombay High Court Orders Removal Of AI Deepfake Content On Shilpa Shetty’ (Verdictum, 27 December 2025), accessed 26 August 2026.

[8]Outlook India, ‘Preity Zinta Deepfake Case Explained: Why Bombay High Court’s Landmark Order Matters Beyond One Actor’ (Outlook India, 8 July 2026), accessed 26 August 2026.

[9]Halder and Basu (n 2).

[10]Nicola Henry and others, Image-Based Sexual Abuse: A Study on the Causes and Consequences of Non-Consensual Nude or Sexual Imagery (Routledge 2020).

[11]Umbach and others (n 1).

[12]Dean Fido and others, ‘Judgement Differences of Types of Image-Based Sexual Harassment and Abuse Conducted by Celebrity Perpetrators and Victims’ (2024) 14(11) Behavioral Sciences 1021, accessed 26 August 2026.

[13]Mondaq (n 6).

[14]Verdictum (n 7).

[15]Halder and Basu (n 2).

[16]Halder and Basu (n 2).

[17]Henry and others (n 10).

[18]Umbach and others (n 1).

[19]Fido and others (n 12).

[20]Henry and others (n 10).

[21]Umbach and others (n 1).

[22]Justice K.S. Puttaswamy (Retd.) v Union of India (2017) 10 SCC 1.

[23]Verdictum (n 7).

[24]Information Technology Act 2000, ss 66C, 66D, 66E, 67, 67A.

[25]Global Law Experts, ‘Deepfake Law India’ (Global Law Experts, 2026), accessed 26 August 2026.

[26]Bharatiya Nyaya Sanhita 2023 (n 4).

[27]Global Law Experts (n 25).

[28]Halder and Basu (n 2).

[29]Mondaq (n 6).

[30]Mondaq (n 6).

[31]LiveLaw, ‘Deepfakes, Due Diligence And The Good Samaritan Paradox: How India’s 2026 IT Amendment Rules Resolve Global Platform Liability Debate’ (LiveLaw, 15 April 2026), accessed 26 August 2026.

[32]Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules 2026, GSR 120(E), r 2(1B).

[33]Digital Personal Data Protection Act 2023.

[34]Medianama, “Morphing Woman’s Image Is An Assault On Privacy, Says Madras HC” (Medianama, 2 July 2026), accessed 26 August 2026.

[35]Medianama (n 34).

[36]Shilpa Shetty Kundra v Getoutlive.in 2025 SCC OnLine Bom 5486.

[37]Verdictum (n 7).

[38]Outlook India (n 8).

[39]Gulf News, ‘Aishwarya Rai Bachchan Moves Delhi High Court Over Misuse Of Her Image By AI’ (Gulf News, 2025), accessed 26 August 2026.

[40]Medianama (n 34).

[41]Fido and others (n 12).

[42]Halder and Basu (n 2).