34.
It is submitted that the extensive public reach, goodwill, and
reputation that the plaintiff has built for himself is further evidenced by the
multitude of prestigious accolades bestowed upon him. The plaintiff has
received numerous awards, honours, and recognitions over the course of his
distinguished career spanning public service, literature, diplomacy, and
public discourse. These accolades have been conferred by reputed national
and international institutions in recognition of the plaintiff‟s contributions to
literature, public life, international relations, and intellectual thought
leadership.
35.
It is submitted that in or around March, 2026, the plaintiff discovered
a sophisticated, malicious campaign orchestrated by unknown infringers,
i.e., defendant no. 1 across various digital platforms. Further, the infringers
have weaponized artificial intelligence and machine learning to generate
hyper-realistic audio-visual deepfakes by cloning the plaintiff‟s face, voice,
vocabulary, and mannerisms. These fabricated videos maliciously depict the
plaintiff making politically sensitive statements that he never made,
including “Pakistan is faring much better diplomatically than India” and
praise for Pakistan‟s diplomatic strategies as “absolute brilliance”. Such
content is calculated to mislead the public and has caused serious harm to
the plaintiff‟s credibility, reputation, and public standing, resulting in
significant mental anguish and harassment.
36.
It is further submitted that accordingly, upon becoming aware of the
unknown infringers‟ unlawful activities, the plaintiff promptly took steps to
seek redressal through available channels, and on 02nd April 2026, the
plaintiff issued Letters to the Secretary of defendant no. 4 and the
Commissioner of Police, Delhi Police, bringing the infringing content and
Page 6 of 12
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