Bombay High Court : AI-Based Celebrity Voice Cloning Unlawful, Grants Interim Protection to Asha Bhosle Against Unauthorized Use of Her Voice and Likeness
Isabella Mariam
The High Court of Bombay, Single Bench of Justice Arif S. Doctor, held that providing Artificial Intelligence (AI) tools that enable conversion of any voice into that of a celebrity without consent amounts to a violation of personality rights. The Court was hearing a suit by legendary playback singer Asha Bhosle, who challenged companies accused of developing and offering AI-based applications that cloned her distinctive voice to generate songs and content, while also using her image and likeness in merchandise, posters, and online promotions without authorization. The Court granted ad-interim injunctions restraining such activities and directed removal of infringing material.
In addition to the AI-generated voice cloning, the plaintiff alleged that her name, image, and likeness were also used without authorization for merchandise, posters, and promotional material on various online platforms. The defendants allegedly facilitated these activities by hosting, promoting, and selling such content and products.
The plaintiff argued that such acts amounted to misappropriation of her personality and publicity rights, constituting unlawful exploitation for commercial gain. She sought urgent injunctive relief to restrain the defendants from continuing these activities, asserting that the unauthorized cloning of her voice and use of her image was likely to mislead the public and cause irreparable harm to her reputation.
The defendants included companies providing AI-based applications, as well as digital platforms enabling the distribution and promotion of the alleged infringing content. Evidence placed before the Court included screenshots, promotional materials, and online listings that depicted the plaintiff’s image and demonstrated the AI tools’ capability to reproduce her voice.
The case primarily involved interpretation of personality and publicity rights, particularly in the context of emerging AI technologies. The plaintiff sought ad-interim injunctions against the defendants to prevent further exploitation of her persona and requested directions for the removal of all infringing content from online platforms.
Justice Arif S. Doctor observed that the case involved unauthorized use of a celebrity’s persona and the application of personality rights in the context of new technologies. The Court recorded: “Making available AI tools which allow the conversion of any voice into that of a celebrity without consent amounts to a violation of personality rights.”
On the evidence presented, the Court noted: “The materials placed on record show that the defendants’ platforms hosted and promoted content generated using the plaintiff’s voice and likeness without her permission.”
The Court further recorded: “Personality rights encompass the right of an individual to control the commercial use of their identity, including their name, image, likeness, and voice.”
Addressing the public perception aspect, the Court stated: “The unauthorized cloning of the plaintiff’s voice and use of her likeness in merchandise and online promotion creates a false impression of her association with such activities, which is impermissible.”
The Bench also acknowledged the role of technological intermediaries, observing: “Online platforms that host or facilitate dissemination of such infringing content cannot escape responsibility once they have notice of the wrongful acts.”
The Court stated: “The plaintiff has made out a strong prima facie case of violation of her personality and publicity rights. If the defendants are not restrained, the plaintiff will suffer irreparable harm.”
The Court concluded: “The balance of convenience lies in favour of granting protection to the plaintiff’s persona against unauthorized use through AI tools and associated online promotions.”
The Court directed: “The defendants are restrained by an ad-interim injunction from in any manner using or making available AI tools that clone or reproduce the plaintiff’s voice without her consent. The defendants shall not use the plaintiff’s name, image, or likeness for any merchandise, posters, or promotional materials without prior authorization.”
“All online platforms are to remove any infringing content featuring the plaintiff’s AI-cloned voice or likeness and shall provide details of the subscribers responsible for uploading such content.”
Advocates Representing the Parties
For the Petitioners: Mr. Ankit Lohia a/w Mr. Vikram Trivedi, Mr. Rashid Boatwalla, Ms. Lipsa Unadkat and Ms. Garima Jain, Advocates i/b Manilal Kher Ambalal & Company
For the Defendants: Ms Charu Shukla and Ms Amishi Sodani i/b Ms Charu Shukla for Defendant No.6
Case Title: Asha Bhosle v. Mayk Inc. & Others
Case Number: Interim Application (L) NO. 30382 OF 2025 in Commercial IP Suit (L) No. 13215 of 2025
Bench: Justice Arif S. Doctor
