Conversion Of Voice Into That Of Celebrity Violates Personality Rights: Bombay High Court Grants Relief To Asha Bhosle Against AI Misuse

The Bombay High Court has protected the personality rights of eminent playback singer Asha Bhosle against the misuse of Artificial Intelligence (AI).

A Commercial IP (Intellectual Property) Suit was filed seeking protection of her personality rights including her name, voice, signatures, photographs, images, and caricatures.

A Single Bench of Justice Arif S. Doctor observed, “In my prima facie view, making AI tools available to enable the conversion of any voice into that of a celebrity without his/her permission would constitute a violation of the celebrity’s personality rights. Such tools facilitate the unauthorized appropriation and manipulation of a celebrity’s voice, which is a key component of their personal identity and public persona, and such technological exploitation not only infringes upon the individual’s right to control and protect their own likeness and voice but also undermines their ability to prevent commercial and deceptive uses of their identity.”

The Bench said that Bhosle is a pre-eminent personality in the field of music and has made out a case for the grant of ad-interim reliefs.

Advocate Ankit Lohia appeared on behalf of the Applicant/Plaintiff, while Advocate Charu Shukla appeared on behalf of the Respondents/Defendants.

Facts of the Case

The Plaintiff sought reliefs against the alleged unauthorised/unlicensed use and/or commercial exploitation of her personality rights. The Suit also pertained to the violation of the Plaintiff's moral rights, which vested in respect of her performances by virtue of Section 38-B of the Copyright Act, 1957. The counsel for the Plaintiff submitted that she enjoys immense respect, prestige and goodwill both nationally and internationally and has a staggering repertoire of songs comprising various different genres, including film music, pop, ghazals, classical music, devotional songs, etc.

Court’s Observations

The High Court after hearing the contentions of the counsel, noted, “The Applicant/Plaintiff therefore, entitled to protection of her personality rights, including the Applicant/Plaintiff’s name, voice, photograph/caricature, image, likeness, persona, and other attributes of her personality. Basis the material upon which reliance has been placed and what has been attributed to Defendant Nos. 1, 2 and 5 in the Plaint in my prima facie makes clear that Defendant Nos.1, 2 and 5, are unauthorizedly using the Applicant/Plaintiff’s personality rights.”

The Court remarked that the conduct of the Defendants is purely unauthorized and infringing of the Plaintiff’s personality rights.

“It is for this reason that I find that the Applicant/Plaintiff has made out a strong prima facie case for the grant of ad-interim relief. The balance of convenience is also entirely in favour of the Applicant/Plaintiff and I am satisfied that if the ad-interim relief is not granted, the Applicant/Plaintiff would suffer irreparable injury”, it added.

Court’s Directions

The Court, therefore, issued the following directions –

• Pending the hearing and final disposal of the Suit, Defendants shall be restrained by a temporary order of injunction from utilizing, exploiting and/or dealing with and/or violating the Applicant’s Personality Rights and/or Publicity Rights and/or moral rights and/or Passing off their goods and services as those emanating from or being endorsed by the Applicant by utilizing and/or in any manner, directly or indirectly, using or exploiting or misappropriating the Applicant’s name, voice/vocal style and technique/vocal arrangements and interpretations, mannerism/ manner of singing, photograph, image or its likeness, signature, persona and/or any other attributes of her personality, for any commercial and/or personal gain.

• Pending the hearing and final disposal of the Interim Application, Defendants shall take down/remove/disable access to all listings/pages identified in the Plaint, which display, advertise, promote and/or offer for sale posters, wallpapers, portraits, caricatures, merchandise or other goods bearing the Plaintiff’s name, image, photograph, and likeness, within a period of one week.

• In the event the Applicant/Plaintiff notifies Defendants in writing of any further infringing listings/pages of a similar nature appearing on their platforms/websites which exploit her name, image, likeness, photograph or caricature without authorization, they shall, similarly take down/remove/disable access to such infringing listings/pages, subject to their right to communicate to the Plaintiff, with reasons, any objection to such removal.

• Defendants shall, upon request and subject to any restrictions furnish to the Plaintiff the basic subscriber/seller information in their possession including name, address, email ID, contact number, IP logs, registration details and payment details of the sellers/uploaders of the infringing listings/content so notified, to enable the Plaintiff to either implead them as parties to the present proceedings or place there relevant details before the Court in those instances where found necessary.

• Defendants shall takedown the specific URLs annexed to the Plaint.

Accordingly, the High Court granted relief to the Plaintiff and listed the case on October 13, 2025.

Cause Title- Asha Bhosle v. Mayk Inc (Case Number: INTERIM APPLICATION (L) NO. 30382 OF 2025)

Appearance:

Plaintiff: Advocates Ankit Lohia, Vikram Trivedi, Rashid Boatwalla, Lipsa Unadkat, and Garima Jain.

Defendants: Advocates Charu Shukla and Amishi Sodani.

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