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 Page 7 of 12 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/07/2026 at 00:55:28

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