the available relevant details to their notice and seeking immediate
takedown and action.
37.
It is submitted that contrary to the depiction in the impugned
deepfakes, the plaintiff has never made any such statements, nor has he
authorized any person or entity to issue such communications on his behalf.
As such, the audio track accompanying the video is entirely synthetic,
generated through voice-cloning tools designed to mimic the plaintiff‟s
precise oratorical cadence and phonetic identity, with the deliberate intent of
deceiving the public into believing the plaintiff actually uttered fabricated
words.
38.
It is submitted that the dissemination of these deepfakes has caused
continuous and severe harm to the plaintiff‟s reputation, and although
several media organisations such as India Today and Press Trust of India, as
also D-Intent Data, i.e., an independent fact checking agency have debunked
the videos, however, the algorithmic amplification and re-sharing on
platforms like X (formerly Twitter) and Meta (Instagram and WhatsApp)
has led to exponential circulation. The forgery is so realistic that it has
deceived unsuspecting members of the public, the political establishment, as
well as various foreign journalists, escalating the matter into an international
embarrassment.
39.
It is submitted that supporters of the plaintiff have also reached out to
him expressing anguish over the false statements attributed to him in these
deepfake videos, resulting in significant harm to his political goodwill.
Further, it is submitted that, as the plaintiff was actively campaigning for the
Kerala Legislative Assembly elections, 2026 in March and early April, the
disinformation campaign was especially damaging, and was a deliberate
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