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 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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