Regulatory Framework Of Deepfakes And Voice Cloning In India - Scope For A New Legislation

Author: LawSphereX

Category: Administrative & Regulatory Law

Published: 2026-08-23T20:54:08.59151+00:00

Updated: 2026-08-26T17:09:46.904+00:00

REGULATORY FRAMEWORK OF DEEPFAKES AND VOICE

CLONING IN INDIA: SCOPE FOR A NEW LEGISLATION

Adithyan S, BA LLB (Hons.), CHRIST (Deemed to be University), Bangalore)

ABSTRACT

This research examines the ever-growing legal challenges posed by Deepfake and Voice Cloning technologies within the Indian context. While these AI-driven technologies offer a wide array of benefits in various arenas such as entertainment and education, they simultaneously facilitate unprecedented risks if not regulated correctly. This paper, analyses the current regulatory framework in India, specifically the IT Act (2000), Bharatiya Nyaya Sanhita (2023), DPDP Act, and the Copyright Act combined with an analysis of the best practices from international jurisdictions, including the US, China, UK, and Australia to cull out the best possible way to regulate this ever-growing field, in India. This paper argues for the urgent implementation of a dedicated, comprehensive legislation in India to safeguard democratic integrity and individual rights in the age of Deepfakes and Voice Cloning.

Keywords: Deepfakes, Voice cloning, India, Artificial Intelligence (AI), legislative framework.

Introduction The growth of AI has been swift and groundbreaking; from not knowing what is AI the world went to the fear of losing jobs to AI. Deepfake and Voice Cloning are two AI based technologies that has spread like a wild fire in the world. Deepfake can be defined as an image or recording that has been convincingly altered and manipulated to misrepresent someone as doing or saying something that was not actually done or said. 1 The word voice cloning surprisingly has not found it’s place in any of the major dictionaries like Oxford and Merriam-Webster yet, in general terms voice cloning can be defined as artificially creating a replica of someone’s voice. Deepfake and voice cloning provides a wide array of uses ranging from its avid use in the movie industries for technologies like de-aging to satirical uses that we get to constantly see on platforms like Instagram and YouTube.

This swift evolution of the said technologies also poses a wide range of risks and threats to democratic processes, privacy, and public trust. The said technologies enable the creation of hyper realistic videos that are seldom possible for human eyes to differentiate from reality. A hyper realistic video of deepfake video of U. S President Donald Trump singing in a crowded concert can be just a satire, only until it is used for other purposes. While their positive applications in movie-making and learning environments cannot be doubted, their negative uses in spreading false information, carrying out sophisticated fraud schemes, and generating non-consensual explicit content are a serious threat. In India, a land with massive and heterogeneous populations increasingly networked by digital media, these threats are especially acute.

The absence of a dedicated, all-encompassing legislative code to address the challenges of deepfakes and voice cloning leaves a wide legislative vacuum, forcing authorities to resort to an array of available laws that are illequipped to the digital world. This research will examine the weaknesses of the existing regulatory framework in India, exploring how provisions of the existing legislations like Information Technology Act of 20002, Bharatiya Nyaya Sanhita 20233, DPDP act4, Indian Copy right Act5 etc, offer only limited remedies. Through an analysis of existing regulatory framework in India and an analysis of international legislations in The United States, China, United Kingdom and Australia this research aims to discover best practices and innovative regulatory alternatives. The overall aim is to push for new, exclusive legislation specifically 1 Deepfake, MERRIAM-WEBSTER.

COM DICTIONARY, https://www. merriamwebster. com/dictionary/deepfake (last visited Sept. 21, 2025).

2 Information Technology Act, 2000, No. 21 of 2000, Acts of Parliament, 2000 (India).

3 Bharatiya Nyaya Sanhita, 2023, No. 45, Acts of Parliament, 2023 (India).

4 Digital Personal Data Protection Act, 2023, No. 22, Acts of Parliament, 2023 (India).

5 Copyright Act, 1957, No. 14, Acts of Parliament, 1957 (India).

designed to counter the unique challenges of deepfakes and voice cloning in the Indian scenario.

1. An Analysis of India's Existing Legal Framework and Its Inadequacies

The main aim of this paper is to gauge the regulatory framework of the existing legal and regulatory framework of deepfakes and voice cloning in India and propose recommendations to make the existing framework more efficient. In order to do the same, it is pertinent to know what exactly are the laws and regulations that deals with deepfakes and voice cloning in India. Currently deepfakes and voice cloning in India is regulated by a combination of statutes not by a single legislation. There are different aspects of deepfakes and voice cloning that different statutes look into. When one thinks about deepfakes, one of the first thing that strikes one’s mind maybe its misuse for creating sexually explicit contents; however, this is just one of the many problems that arise out of the misuse of these AI technologies.

We will have a look at different statutes that deals with the regulation of deepfake and voice cloning, while keeping a close eye on the what aspect of the same is being dealt by the statute. i. Information Technology Act 2000 (IT Act 2000)6 IT Act 2000 is the primary cyber legislation in India. Being a legislation with extra territorial jurisdiction, the act not only deals with the cyber offences committed in India but also the offences committed on India from a foreign country. 7 Furthermore, section

758 of the IT Act also talks about the extra territorial application of the act. The extra

territorial application of the act is an important feature as cybercrimes most of the times blurs the boundaries between countries and an effective counter of the same would be a collective global move against such crimes. Crimes arising out of deepfakes and voice cloning being no exceptions, the extra territorial application of the act would really be a helpful feature in countering the same. But it his perhaps concerning to note that the act, being the primary cyber legislation in India, still does not have any mention of ‘deepfakes’ or ‘voice cloning’; section 29 of the act, which is the definitional clause of the act, does not have any mention of the said terms. Even though the act does not

6 6 Information Technology Act, 2000, No. 21 of 2000, Acts of Parliament, 2000 (India).

7 PAVAN DUGGAL, CYBER LAW, 2-3 (2nd ed., Universal Law Publishing, Lexis Nexis 2018).

8 Information Technology Act, 2000, § 75, No. 21 of 2000, Acts of Parliament, 2000 (India).

9 Information Technology Act, 2000, § 2, No. 21 of 2000, Acts of Parliament, 2000 (India).

explicitly deal, or even mention deepfakes and voice cloning, the provisions of the act are used in regulation of deepfakes and voice cloning in the country. Various sections of IT act help in regulating the use of deepfakes and voice cloning. We shall have a look at the following important sections of the IT act as well as the aspect they help regulate. • Section 66C10 • Section 66D11 • Section 66E12 • Section 6713 • Section 7914 Section 66C15 of the IT act 2000, deals with the crime of identity theft and prescribes a punishment for a maximum period of three years and a fine which may extend up to 1 lakh rupees. Identity theft is a crime that can easily associated with the misuse of deepfakes and voice cloning technologies; we constantly stumble upon instances of scammers faking persons voice in order to extort money, this is often done with the help of such technologies.

Hence this section of IT act makes sure that identity theft done by any means are punishable under the law. Section 66D16, deals with the offence of cheating by personation by using a computer resource and prescribes a punishment same as section 66C for the offence. In the context of deepfakes and voice cloning sections 66C and 66D together plays an important role in make sure that the said technologies are not used for identity theft and cheating and if done shall be punished accordingly.

10 Information Technology Act, 2000, § 66C, No. 21 of 2000, Acts of Parliament, 2000 (India).

11 Information Technology Act, 2000, § 66D, No. 21 of 2000, Acts of Parliament, 2000 (India).

12 Information Technology Act, 2000, § 66E, No. 21 of 2000, Acts of Parliament, 2000 (India).

13 Information Technology Act, 2000, § 67, No. 21 of 2000, Acts of Parliament, 2000 (India).

14 Information Technology Act, 2000, § 79, No. 21 of 2000, Acts of Parliament, 2000 (India).

15 Information Technology Act, 2000, § 66C, No. 21 of 2000, Acts of Parliament, 2000 (India).

16Information Technology Act, 2000, § 66D, No. 21 of 2000, Acts of Parliament, 2000 (India).

Section 66E17 punishes the violation of privacy; to be more precise, this section punishes the transmission or publishing of private areas of any person without their consent. The punishment for the same may extent up to 3 years in prison and up to 2 lakh rupees fine. This section make may be used when deepfake technology is used to violate one’s privacy. However, in the case of deepfakes, the image that is transmitted, violating one’s privacy is not a real image; hence, if we decide to go by the strict interpretation of the wordings of the section, the actual ‘private part’ would have never been transmitted in the instance of deepfake. However, if the courts decide to use a liberal interpretation of the section, the same shall be used for offences arising out of deepfakes as well. The non-mention of ‘deepfake’ in the act will give rise to such legal gaps and ambiguities.

Section 6718 deals with the publishing or transmitting of obscene material online. This section criminalizes one of the most popular misuses of deepfake and voice cloning technologies, that is, the publishing and transmission of obscene and sexually explicit contents. The section punishes the offence with 3 years’ imprisonment and up to 5 lakh rupees fine. Even though the section criminalizes the publishing and transmission of the obscene materials, the act does not talk about the creation of the same using AI technologies as a separate and punishable offence; this leaves a major gap to fill in the existing legal framework as the mere creation of such material even for personal use may violate the right to privacy of the people. It is pertinent to note that right to privacy has been declared a fundamental right in the famous K S Puttaswamy Case (2018).

19 Section 7920 of the act exempts the intermediary from liability if the intermediary has performed due diligence and acted in compliance with the guidelines and rules set by the central government. This section, when couples with Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 202121, plays and important role in regulating the use of deepfakes and voice cloning. As per the abovementioned IT rules places obligations on the intermediaries to do due diligence and to

17 Information Technology Act, 2000, § 66E, No. 21 of 2000, Acts of Parliament, 2000 (India).

18 Information Technology Act, 2000, § 67, No. 21 of 2000, Acts of Parliament, 2000 (India).

19 Justice K.S. Puttaswamy (Retd.) & Anr. v. Union of India & Ors., (2018), AIR 2018 SC (SUPP) 1841.

20 Information Technology Act, 2000, § 79, No. 21 of 2000, Acts of Parliament, 2000 (India).

21 Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, G.S.R. 139(E), Gaz. of India, Extra., Part II, Sec. 3(i), 20 (India).

apply swift and efficient redressal mechanism such as acknowledgement of a complaint within 24 hours and resolving the same within 15 days from the date of receipt. 22 ii. Digital Personal Data Protection Act23 The Digital Personal Data Protection Act, 2023 is another key legislation that is used for regulating deepfakes in India as it regulates processing of personal data of individuals. In essence, the Act mandates that bodies, as Data Fiduciaries, first secure explicit authorization from individuals, as Data Principals, before processing personal data for purposes specified. An individual's face and voice are personal and usually sensitive biometric data; the Act is thus anticipated as providing an appreciable framework of protection. Section 424 of the act deals with the grounds for processing personal data and lays down that it shall be used only for lawful and legitimate purposes.

Section 625 upholds the importance of valid consent and lays down that date shall be used only after acquiring valid consent from the data principal. Even though the act upholds the importance of consent a legitimate use of data, the acts fall short in one aspect when it comes to deepfakes and voice cloning. The act does not forbid any use of publicly available data. For example, if a person’s voice or video is available in the public domain and someone uses it to create a deepfake or do voice cloning, the same shall be legal under this act as the act deals only with personal and private data and not the ones that is available in the public domain. iii. Bharaiya Nyaya Sanhita, 2023 (BNS)26 The Bharatiya Nyaya Sanhita, 2023, is the primary criminal legislation of the country.

The same coupled with IT Act 2000 is used to punish criminal acts arising out of the misuse of deepfakes and voice cloning. It criminalizes acts such as criminal defamation, 22 Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, r. 3, G. S. R. 139(E), Gaz. of India, Extra. , Part II, Sec. 3(i), 20 (India).

23 Digital Personal Data Protection Act, 2023, No. 22, Acts of Parliament, 2023 (India).

24 Digital Personal Data Protection Act, 2023, § 4, No. 22, Acts of Parliament, 2023 (India).

25 Digital Personal Data Protection Act, 2023, § 6, No. 22, Acts of Parliament, 2023 (India).

26 Bharatiya Nyaya Sanhita, 2023, No. 45, Acts of Parliament, 2023 (India).

forgery, cheating by personation, outraging the modesty of a women etc. Section 35627 criminalizes criminal defamation. This section shall be made applicable whenever deepfakes are used to defame a person. Section 31828 criminalizes cheating by personation; this shall be read with section 66D29 of the IT Act 2000. Section 33630 criminalizes forgery, this section shall be used to make sure that deepfakes and voice cloning are not used for forging fake data. Furthermore, section 7731 and section 7932 of the act criminalizes voyeurism and acts that outrage the modesty of the women and hence deterring any criminal use of technology against the privacy of women. Even though BNS deals with certain crimes that arise out of deepfake, there is no mention of the term ‘Deepfake’ or ‘Voice Cloning’ anywhere in the act.

The act majorly focuses only on certain after effects of criminal use of the technologies rather than focusing on the criminal act itself. As mention earlier with respect to IT Act 2000, even BNS does not criminalize the use of deepfake and voice cloning for the creation of even unlawful material, it shall be a crime only if the same is published. This raises serious concerns as this legal lacuna and ambiguity paves way for the direct violation of right to privacy of the people. iv. The Copyright Act 1957. 33 The copyright act deals with the protection of creator rights. This act is another way to counter misuse of deepfakes. Section 5134 of the act defines copyright infringement, and the same also means creation of an unauthorized copy of a copyrighted work.

Furthermore, section 5735 of the act also provides moral rights to the creators, as per which they can make sure that their original works are not tampered with in a way which negatively effects their work or reputation. Hence as per this act, the misuse of AI technologies to create fake copies of copyrighted material can be countered.

27 Bharatiya Nyaya Sanhita, 2023, § 356, No. 45, Acts of Parliament, 2023 (India).

28 Bharatiya Nyaya Sanhita, 2023, § 318, No. 45, Acts of Parliament, 2023 (India).

29 Information Technology Act, 2000, § 66D, No. 21 of 2000, Acts of Parliament, 2000 (India).

30 Bharatiya Nyaya Sanhita, 2023, § 336, No. 45, Acts of Parliament, 2023 (India).

31 Bharatiya Nyaya Sanhita, 2023, § 77, No. 45, Acts of Parliament, 2023 (India).

32 Bharatiya Nyaya Sanhita, 2023, § 79, No. 45, Acts of Parliament, 2023 (India).

33 Copyright Act, 1957, No. 14, Acts of Parliament, 1957 (India).

34 Copyright Act, 1957, § 51, No. 14, Acts of Parliament, 1957 (India).

35 Copyright Act, 1957, § 57, No. 14, Acts of Parliament, 1957 (India).

The lacuna in this act is that only the copyright owner shall have the said rights; if someone uses AI to create a deepfake or voice clone of a singer’s voice, unless the product infringes the copyright of the song, the same shall not be punishable. In essence the act only provides legal protection for the artwork created and not personality rights to the artists. v. Case Laws Just like the lack of an exclusive legislation and exclusive provision for deepfakes and voice cloning, even the judicial pronouncements and interpretation of the same are in the budding stages. As of date there has been no major judgment from the hon’ble Supreme Court that deals with the said technologies. However, cases have started coming up in the High Court, highlighting the beginning of judicial interpretations of the said technologies, which is an absolute need of the hour. Arijit Singh v.

Codible Ventures LLP36 (Bombay High Court) In this case, Bombay High Court granted interim relief to singer Arijit Singh against unauthorized AI platforms and using his voice for cloning and creating content. The court recognized the singer’s personality rights, including his voice, vocal style and mannerisms as protectable attributes. 37This is one of the first cases that dealt with voice cloning in India. The court granted an interim relief for the famous singer in this case. 38 Anil Kapoor v. Simple Life India & Ors (2023)39 (Delhi HC) In this case Anil Kapoor, yet another celebrity like Arijit Singh filed for an ex-parte injunction on grounds that his mages and voices, was used for generating AI images and were used for merchandise and endorsement. 40 This case is one of the first Indian judgement directly addressing the misuse of deepfakes and its intersection with

36 Arijit Singh v. Codible Ventures LLP, 2024 SCC OnLine Bom 2445

37 Simranjeet, 'AI tools infringe individual's right to control and protect their own likeness/voice'; Bombay HC grants ad-interim injunction in favour of Arijit Singh to protect his personality rights, SCC ONLINE BLOG (Aug. 2, 2024), https://www.scconline.com/blog/post/2024/08/02/bomhc-grants-ad-interim-injunction-to-arijitsingh-to-protect-his-personality-rights/ (last visited Sep. 21, 2025).

38 Id.

39 Anil Kapoor v. Simply Life India, 2023 SCC OnLine Del 6914.

40 Id

intellectual property and personality rights. Ankur Warikoo and Anr. V. John Doe and Ors (2025)41 Yet another Delhi High Court case where interim relief was granted in petitioner’s favours at his personality rights infringed using AI.42 Even though cases in this regard have starting popping out one by one, there is still neither a landmark Supreme court judgment addressing the same, neither is there a legislation or statute. And upon having a close look on the relief provided by High court, it is mainly interim relieves, however, is this really the way to go about it? And what about the personality rights of general public, is it not worth being protected? Should there not be more stringent measures to curb the misuse by AI and violation of personality rights? All these questions are yet to be answered by our lawmakers and judiciary.

2. Comparative Review of International Regulatory Approaches to Deepfakes

Now that we have gained a fair idea about the current Indian regulatory framework with regards to deepfakes and voice cloning, let’s have a look at how various foreign legislations approach the same. i. United States of America Unlike India the USA is already on the movie to come up with specific legislation with respect to AI technologies such as deepfakes and voice cloning. One notable move is the Deepfakes Accountability Act (2023).43 Officially known as the "Defending Each and Every Person from False Appearances by Keeping Exploitation Subject to Accountability Act of 2023", the "DEEPFAKES Accountability Act," is a bill introduced in the U.S. House of Representatives to

41 Ankur Warikoo v. John Doe, 2025 SCC OnLine Del 3727.

42 Editor, Delhi High Court grants 'John Doe' injunction to Ankur Warikoo to protect his personality rights from misuse through AI and deepfake technology, SCC ONLINE BLOG (May 29, 2025), https://www.scconline.com/blog/post/2025/05/29/delhi-high-court-ankur-warikoo-john-doe-injunctiondeepfake-ai-misuse-legal-news/ (last visited Sep. 21, 2025).

43 DEEPFAKES Accountability Act, H.R. 5586, 118th Cong. (2023).

address threats from deepfake technology. 44 The proposed act defines deepfakes as follows, “Any video recording, motion-picture film, sound recording, electronic image, or photograph, or any technological representation of speech or conduct substantially derivative thereof— “(A) which appears to authentically depict any speech or conduct of a person who did not in fact engage in such speech or conduct; and “(B) the production of which was substantially dependent upon technical means, rather than the ability of another person to physically or verbally impersonate such person”. 45 Certain notable provisions of the acts include the mandatory disclosure of contents that were made using AI.

This disclaimer will solve a lot of problems pertaining to deepfakes as one of the major problems around the said technology is people being unable to demarcate between AI made content and real-life contents. Another notable provision is deepfake victim assistance. 46 This proposed act, by clearly defining deepfakes and ensuring things like transparency and accountability while punishing the misuse of such technologies will turn out to be a landmark legislation the world can look up to once enacted. The act, even though in it’s processing stages, is a landmark move and holds lot of take aways for a country like India, which is still in its budding stage with respect to AI regulations. ii. United Kingdom Even though U.

K have not yet come up with an exclusive legislation for deepfakes and voice cloning, they have enacted the Online Safety Act 2023, which aims to make the cyber space safer for the citizens. 47 The acts seek to achieve this goal majorly by increasing the duty of care on part of online service providers, which

44 H.R.5586 - 118th Congress (2023-2024): DEEPFAKES Accountability Act, CONGRESS.GOV, (Sept. 20,

2023), https://www.congress.gov/bill/118th-congress/house-bill/5586/text (last visited, Sept. 21, 2025)

45 Id.

46 H.R.5586 - 118th Congress (2023-2024): DEEPFAKES Accountability Act, CONGRESS.GOV, (Sept. 20,

2023), https://www.congress.gov/bill/118th-congress/house-bill/5586/text (last visited, Sept. 21, 2025)

47 Online Safety Act 2023, c. 50.

includes social media platforms and search engines. 48 To enhance the duty of care, transparency and accountability some platforms will have to comply with additional requirements. 49 Even though the act does not exclusively deal with technologies such as deepfakes and voice cloning, the provisions of the act directly helps in regulating the same. By enforcing a higher burden of duty of care on the online platform, the act ensures that the modern technologies are not used for unlawful purposes. iii. People's Republic of China China is well ahead when it comes to international race of AI regulation. The Chinese government enacted the Deep Synthesis Regulation Act, way back in November 2023, and the same came into effect in January 2023. 50 This act exclusively deals with the regulation of deep synthesis technologies like deepfakes and voice cloning.

The act lays down various efficient and pinpoint provisions to regulate the use of deep synthesis technologies. The major provisions include the mandatory identity verification of the users of such technologies; the act mandates that such technologies should only be made available to verified individuals. 51 This provision solves a major problem that pertains to the misuse of AI, that is, tracking that actual perpetrator. With the help of mandatory verification, individuals shall be made personally liable for their acts. The act also strictly prohibits the misuse of AI for creating materials that violates the integrity as well as morals of the nation. 52 Furthermore, the act also prohibits the use of deep synthesis technologies to create content that violates personal rights of the citizens. 53 This act provides strict rules and regulations for the use of deep synthesis AI technologies.

The act, while effectively prohibiting the potential misuses of the technologies also enables the use 48 Online Safety Act: explainer, GOV. UK, (Apr. 24, 2025), https://www. gov. uk/government/publications/onlinesafety-act-explainer/online-safety-act-explainer (last visited, Sept. 21, 2025).

49 Id.

50 Cyberspace Administration of China, Ministry of Industry and Information Technology of the People's Republic of China & Ministry of Public Security of the People's Republic of China, Provisions on the Management of Deep Synthesis of Internet Information Services, CHINA INTERNET INFORMATION OFFICE (Dec. 11, 2022), https://www.cac.gov.cn/2022-12/11/c_1672221949354811.htm (last visited Sep. 21, 2025).

51 Id.

52 Id.

53 Id.

of the same in a lawful manner. iv. Australia Australia is yet another country that is just starting to set their foot in the realm of AI regulations. They have not yet come up with any exclusive legislations for deepfakes and voice cloning; However, the government of Australia had recently amended their criminal code to criminalize deepfake sexual materials.54

3. Recommendations for a Comprehensive and Efficient Regulatory Framework for

Deepfake and Voice Cloning in India As one may observe from the analysis of the existing legal framework in India with regards to deepfakes and voice cloning, there exists a lot of ambiguity and lacuna. India, currently working on a patchwork of various existing legislations to deal with the same, overlooks the root cause of the problems and are more concentrated on just punishing the after effects. While acts like the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 202155 do contain provisions which aims to ensure duty of care and accountability on the intermediaries, it being not backed by any sanctions raises questions on the effectiveness and efficiency of the same. Furthermore, just like the statutory lacking, the judicial interpretations and pronouncements regarding the same are also in its budding stages, hence leaving a legal void.

The filling of this legal void is the need of the hour owing to the rapid growth of AI technologies in the world. To effectively regulate AI technologies like deepfakes and voice cloning, India may implement one among the two methods suggested. i. Amend the existing laws to include specific AI regulatory Provision. One way to go about it is to effectively amend the existing laws that are being used currently to make them ‘up to date’. For example, defining the term ‘Deepfakes’ and ‘Voice Cloning’ in the IT Act56 and further adding specific provisions for the regulation of the same rather that relying upon the method of liberal interpretations.

54 Criminal Code Amendment (Deepfake Sexual Material) Act 2024 (Cth) No 78, 2024.

55 Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, G.S.R. 139(E), Gaz. of India, Extra., Part II, Sec. 3(i), 20 (India).

56 Information Technology Act, 2000, No. 21 of 2000, Acts of Parliament, 2000 (India).

While amending the existing legislations it is absolutely important to fill the existing legal gaps, for example answering the question whether the mere creation of an illegal deepfake content would be a crime in itself? The amendments should also find solutions to the upcoming problems such as providing personality rights to even common citizens, ensuring transparency and accountability from both the users and the platforms etc. India may incorporate various provisions from the foreign legislations discussed above, such as ‘mandatory verification’ from the Chinese Deep Synthesis Regulation Act57 and ‘the mandatory disclosure’ provision from the US Deepfakes Accountability Act. 58 However, amending all the existing legislations with respect to deepfakes and voice cloning will be a tiresome and time consume process as there exist multiple legislations that deals with its regulations.

Even so, amending of certain legislations can be considered as a good option to meet the current needs and requirements and shall be used till a specific and exclusive legislation is passed by the parliament, India may take inspiration from Australia for the same. ii. Promulgate an Exclusive Legislation for the Regulation of AI India may follow the example of China and promulgate an exclusive legislation for the regulation of AI technologies such as deepfakes and voice cloning. The same shall be done after appointing a committee to critically analyse the existing foreign legislations that pertains to the same and also to make India specific laws that takes into account the cultural and societal structure of the country.

As already mentioned above, relevant and usable provisions from the Chinese Deep Synthesis Regulation Act59, US Deepfakes Accountability Act60 and UK Online Safety61 acts shall be 57 Cyberspace Administration of China, Ministry of Industry and Information Technology of the People's Republic of China & Ministry of Public Security of the People's Republic of China, Provisions on the Management of Deep Synthesis of Internet Information Services, CHINA INTERNET INFORMATION OFFICE (Dec. 11, 2022), https://www. cac. gov. cn/2022-12/11/c_1672221949354811. htm (last visited Sep. 21, 2025).

58 DEEPFAKES Accountability Act, H.R. 5586, 118th Cong. (2023).

59 Cyberspace Administration of China, Ministry of Industry and Information Technology of the People's Republic of China & Ministry of Public Security of the People's Republic of China, Provisions on the Management of Deep Synthesis of Internet Information Services, CHINA INTERNET INFORMATION OFFICE (Dec. 11, 2022), https://www.cac.gov.cn/2022-12/11/c_1672221949354811.htm (last visited Sep. 21, 2025).

60 DEEPFAKES Accountability Act, H.R. 5586, 118th Cong. (2023)

61 Online Safety Act 2023, c. 50.

looked into and incorporated in the proposed new legislation, Conclusion In conclusion, this paper highlights the critical need for a thorough and proactive regulatory framework in India to confront the emerging challenges posed by deepfake and voice cloning technologies. The current legal framework consists of a lot of legal lacunae as pointed out, resulting in a substantial legal void. Although revising existing laws presents a potential shortterm solution, this research primarily pushes for the establishment of a dedicated, exclusive statute that is specifically made for the Indian background.

Such legislation should be developed through a comprehensive comparative analysis of existing foreign legislations, considering models like the compulsory verification rules outlined in the Chinese Deep Synthesis Regulation Act and the mandatory disclosure stipulations within the US Deepfakes Accountability Act, and thereby ensuring a comprehensive strategy for the protection of individual rights, public confidence, and democratic integrity in the digital age.