attempt to tarnish his patriotic credentials, manipulate public perception, and unlawfully interfere with the democratic electoral process. 40. Learned Senior Counsel for the plaintiff submits that the unauthorized cloning and exploitation of the plaintiff‟s likeness, voice and mannerisms infringe his personality and publicity rights and also constitute a serious violation of his Right to Privacy. Furthermore, the actions of the defendants constitute the common law torts of passing off, misappropriation, and dilution by tarnishment. The creation and dissemination of these manipulated videos also amount to identity theft and forgery under Section 66C of the Information Technology Act, 2000, and Sections 335 and 340 of the Bharatiya Nyaya Sanhita, 2023. 41. It is submitted that in light of the plaintiff‟s highly distinguished background as a former Under-Secretary- General of the United Nations, a former Minister of State for External Affairs, and the Chairperson of the Parliamentary Standing Committee on External Affairs, any statement attributed to him regarding foreign diplomacy carries immense geopolitical weight. There is immense public goodwill associated with his identity. Therefore, by falsely portraying the plaintiff as endorsing the diplomatic positions of a foreign nation, the unknown infringers have not only committed a gross misappropriation of the plaintiff‟s personality rights, but also jeopardized his institutional integrity and diplomatic standing. As such, the impugned deepfakes have caused an irreparable harm to the plaintiff. 42. The matter requires consideration. Accordingly, issue notice to the defendants. 43. Notice is accepted by learned counsels appearing for defendant nos. 3, 4 and 5. Page 8 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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