AI generated video of PM Modi

Patna High Court: In a civil writ petition filed by petitioner seeking removal of AI generated video clipping of PM Narendra Modi and his late mother, a Division Bench of the P. B. Bajanthri, ACJ*, and Alok Kumar Sinha, J., while directing the respondents not to circulate the video clipping until further orders held that, prima facie, humiliating a sizeable class of persons in exhibiting video clip cannot be countenanced in a constitutional democracy governed by the principles of dignity, liberty, and fraternity.

The Court noted that the decisions in K.S. Puttaswamy (Privacy-9J.) v. Union of India, (2017) 10 SCC 1, Naz Foundation v. State (NCT of Delhi), 2009 SCC OnLine Del 1762, National Legal Services Authority v. Union of India, (2014) 5 SCC 438, Ranveer Gautam Allahabadia v. Union of India, 2025 SCC OnLine SC 698 wherein the Supreme Court had the opportunity to examine issues like circulation of defamatory statement etc., read with dignity of life and class of persons fundamental right has been infringed. Also, discussed infringement of Article 14, 19(2) read with Article 21 of the Constitution.

The Court observed that it had to examine the case with reference to the video clipping and its contents to the extent of any violation of Articles 14, 21, and 19(2) of the Constitution.

The Court pointed out that the following points were to be further examined- right to dignity as an integral part of Article 21, reputation and good name are facets of the right to life, any attempt to stigmatize or marginalize an entire class of persons offends the guarantee of equality before law under Article 14 and freedom of expression with reasonable restrictions under Article 19(2), intervention of courts when vulnerable groups are subjected to indignity.

The Court observed that, prima facie, humiliating a sizeable class of persons in exhibiting video clip cannot be countenanced in a constitutional democracy governed by the principles of dignity, liberty, and fraternity.

The Court issued notices to the respondents. The Court also issued a directive to the Respondents and others to stall the circulation of the video clipping if it was still in circulation, until further orders. The Court also directed the petitioner to furnish the video clip in the form of a pen drive to the Court and all respondents. The matter was re-listed on 15-10-2025.

[Vivekanand Singh v. Union of India, 2025 SCC OnLine Pat 2933, decided on 17-09-2025]

*Judgment authored by: Justice P. B. Bajanthri, ACJ


Advocates who appeared in this case:

For the Petitioner: Santosh Kumar, Sr. Advocate, Praveen Kumar, Sanjay Kr. Agarwal, Utsav, Raushan Kumar

For the ECI: Siddharth Prasad, Advocate

For the Union of India: K.N.Singh, ASG and Ratish Kumar

For the State: Apurva Kumar, AC to GA12

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