Maritime Boundary Dispute Resolution

INTERNATIONAL COURT OF JUSTICE SPECIAL AGREEMENT BETWEEN THE REPUBLIC OF ARTAVIA (APPLICANT) AND THE STATE OF BELEMI (RESPONDENT) TO SUBMIT TO THE INTERNATIONAL COURT OF JUSTICE THE DIFFERENCES BETWEEN THE PARTIES CONCERNING THE SEAGO VORTEX Jointly notified to the Court on * September * JOINT NOTIFICATION ADDRESSED TO THE REGISTRAR OF THE COURT The Hague, * September * On behalf of Applicant, the Republic of Artavia, and Respondent, the State of Belem, in accordance with Article *(*) of the Statute of the International Court of Justice, we have the honor to transmit to you for submission to the International Court of Justice an original of the Special Agreement of the Differences between the Applicant and the Respondent concerning the Seago Vortex, signed in The Hague, The Netherlands, on the twentieth day of September in the year two thousand twenty-four. (Signed) His Excellency Robert Malcom Ambassador of the Republic of Artavia to the Kingdom of the Netherlands (Signed) Her Excellency Natalia Rodriguez Ambassador of the State of Belem to the Kingdom of the Netherlands * STATEMENT OF AGREED FACTS *. The Seago Vortex is a strategically significant maritime area located in the Northern Seaboard, bordered by the Republic of Artavia to the east and the State of Belem to the west. Covering approximately *,* square kilometers, this region is renowned for its abundant fisheries and substantial mineral resources, including oil and natural gas reserves. For centuries, the Seago Vortex has been a critical fishing ground, sustaining the livelihoods of local communities in both countries. The area's economic importance has grown with the discovery of valuable underwater resources, making it a focal point of national interest for both Artavia and Belem. *. Due to the impacts of climate change, the coastline in the Northern Seaboard has been receding, exacerbating disputes over maritime boundaries between Artavia and Belem. Coastal erosion has had profound socio-economic effects on local communities in both countries. For instance, the Artavian village of Vero has lost over *% of its landmass to the sea over the past decade, displacing more than *,* residents. Similarly, the Belemese town of Lantana has seen its fishing docks submerged, severely disrupting the local fishing industry and resulting in significant economic losses. Additionally, the erosion has led to disputes over the baseline from which territorial waters and exclusive economic zones (EEZ) are measured. *. The receding coastline has altered the physical geography of the region, impacting the baseline from which maritime zones are calculated. Artavia and Belem have each attempted to adjust their baselines to reflect the new realities, leading to overlapping claims. According to UNCLOS Article *, "the normal baseline for measuring the breadth of the territorial sea is the low-water line along the coast as marked on large-scale charts officially recognized by the coastal State." Disputes have arisen over the interpretation of these adjustments, with Artavia claiming that the new baseline should reflect the historic extent of its coastline, while Belem insists on a baseline that corresponds to the current low-water mark. This discrepancy affects the delimitation of their respective EEZs, extending up to * nautical miles from the baseline as per UNCLOS Article *. *. Artavia and Belem, both of which gained independence from colonial rule in the early 20th century, have since developed robust maritime industries. The Seago Vortex has become increasingly crucial to their economies, significantly contributing to their GDPs through both traditional fishing activities and, more recently, oil extraction. Historical documents, including the * Maritime Agreement, reveal that both nations have long asserted claims over the Seago Vortex, leading to a protracted and complex dispute over the rightful ownership and exploitation of its resources. Both countries have engaged in unilateral and joint efforts to explore and exploit these resources, further complicating the legal landscape. *. The * Maritime Agreement between Artavia and Belem is frequently cited by both parties to justify their claims. Artavia argues that the agreement explicitly recognized its sovereignty over the Seago Vortex, while Belem contends that the agreement merely outlined provisional fishing rights without addressing sovereignty. An extract from the * Maritime Agreement states: "Both Parties agree to cooperate in the sustainable exploitation of the Seago Vortex, * recognizing mutual interests in maintaining the viability of the fisheries and other marine resources." *. In *, Belem experienced significant political turmoil when General Hugo Santos, the head of the military, orchestrated a coup against the sitting president, Dr. Maria Fernandez. Both Santos and Fernandez claimed to be the legitimate president of Belem, resulting in the formation of two rival administrations. General Santos established control over the northern regions, including the capital city of Solara, while Dr. Fernandez's government operated from the southern city of Portella. This division led to conflicting international agreements and treaties being signed by the two administrations, affecting the legitimacy and enforceability of these documents. *. The international community was initially divided in its recognition of the two governments. The United Nations and several major powers initially recognized General Santos due to his control over key government institutions. However, reports of human rights violations committed by Santos' forces, including the infamous "Solara Massacre" where * civilians were killed, led many countries to switch their recognition to Dr. Fernandez. By *, the majority of the international community, including Artavia, recognized Dr. Fernandez as the legitimate president of Belem. This shift in recognition has implications for the validity of international agreements and treaties signed by Belem during this period. A * UN Resolution expressed deep concern over the reports of widespread human rights abuses in Belem and acknowledged the administration of Dr. Maria Fernandez as the legitimate representative of the Belemese people. *. General Santos’ administration was accused of committing grave human rights violations, including extrajudicial killings, torture, and arbitrary detention of political opponents. Despite these accusations, Santos invoked immunity as a head of state, arguing that he could not be prosecuted for actions taken in his official capacity. International human rights organizations, such as Amnesty International, documented numerous cases of abuse under his regime. One notable case involved the torture of political activist Elena Marquez, whose ordeal became a rallying point for international condemnation. The legal question of immunity versus accountability for gross human rights violations remains a contentious issue in this context. *. In a press conference, Dr. Maria Fernandez stated, "Our administration is committed to a peaceful resolution that respects international law and the rights of our people. We believe that the ICJ is the appropriate forum for this dispute, and we are ready to present our case." *. In *, Artavia passed a Naturalization by Investment Act (NIA), allowing foreign nationals to acquire Artavian citizenship by making substantial investments in the country. The NIA aimed to attract foreign capital to boost the economy. The program was widely advertised, highlighting the benefits of Artavian citizenship, including visa-free travel to many countries and access to Artavia’s financial services. Notable figures who acquired Artavian citizenship under this program include billionaire investor John Thornton and tech entrepreneur Li Wei. The influx of new citizens and their investments had significant economic and political impacts, affecting domestic and foreign policies. The Artavian Minister of Finance remarked, "The Naturalization by Investment Act has provided substantial economic benefits, allowing Artavia to modernize its infrastructure and improve public services." * *. The Seago Vortex’s resources became a focal point of economic development for both countries. In *, Artavia discovered significant oil reserves in its maritime zone, leading to an economic boom. Belem, under the administration of Dr. Fernandez, sought to expand its fishing industry and initiated joint ventures with international companies, such as the partnership with OceanaCorp, to explore mineral resources in the Seago Vortex. The joint venture with OceanaCorp, for instance, led to the discovery of rare earth minerals critical for high-tech manufacturing. These activities have raised questions about the sustainable and equitable exploitation of shared resources. *. Artavia's discovery of oil reserves has led to an economic boom, but also to increased environmental concerns and disputes with Belem over the delimitation of maritime zones. Belem's joint ventures in the Seago Vortex have similarly led to economic benefits and environmental challenges. An excerpt from the OceanaCorp Partnership Agreement states: "The partnership between Belem and OceanaCorp aims to responsibly explore and extract mineral resources in the Seago Vortex, ensuring minimal environmental impact and equitable profit-sharing." *. Environmental organizations, including Green Earth and Ocean Protectors, raised concerns about the sustainability of resource extraction in the Seago Vortex, calling for stricter regulations to protect the marine environment. These organizations documented a decline in fish populations and the degradation of coral reefs, attributing these issues to overfishing and pollution from oil drilling. The environmental degradation has led to calls for international environmental regulations and the enforcement of existing treaties to protect marine ecosystems. A statement from a Green Earth report highlighted: "The unchecked exploitation of the Seago Vortex's resources has led to alarming rates of fish population decline and coral reef degradation, necessitating immediate international regulatory intervention." *. In *, Artavia, Belem, and other neighboring countries formed the North Sea Regional Organization (NSRO) to promote regional cooperation and address shared challenges, including maritime boundary disputes and environmental protection. The treaty establishing the NSRO included a compromissory clause obligating members to submit disputes to the International Court of Justice (ICJ) for resolution. The interpretation of this clause is now in question, as both Artavia and Belem have sought to invoke it in their ongoing disputes. The legal standing and scope of this compromissory clause are central to the current proceedings. An extract from the NSRO Treaty states: "Member states agree to submit any disputes arising from the interpretation or application of this treaty to the International Court of Justice for final and binding resolution." *. In *, a confrontation occurred between Artavian and Belemese naval vessels in the Seago Vortex. Both sides accused each other of violating their maritime zones and endangering the lives of their personnel. During the incident, the Artavian frigate "Aventura" and the Belemese corvette "Santos II" came dangerously close to collision, with both sides firing warning shots. The incident escalated tensions and led to a series of diplomatic protests and calls for international mediation. The legal implications of these confrontations include potential violations of the United Nations Convention on the Law of the Sea (UNCLOS). An excerpt from UNCLOS Article * emphasizes: "States are required to take all necessary measures to ensure the safety of navigation and to prevent collisions at sea, particularly in disputed maritime zones." * *. In a recent broadcast by the International Maritime News Network, the ongoing tensions between Artavia and Belem were highlighted. The report stated, "The Seago Vortex dispute has reached a critical point, with both nations heavily invested in the outcome. The recent naval incident has only served to deepen the divide, with international observers calling for calm and urging both parties to abide by international legal standards." *. Artavia and Belem engaged in several rounds of negotiations to resolve their differences but were unable to reach an agreement. Both parties accused each other of bad faith and unwillingness to compromise. In *, Artavia unilaterally submitted the dispute to the ICJ, invoking the compromissory clause of the NSRO treaty. Belem initially objected but later agreed to participate in the proceedings under certain conditions. The legal arguments regarding the binding nature of the compromissory clause and the jurisdiction of the ICJ will be pivotal in these proceedings. *. Both Artavia and Belem have agreed to submit their disputes to the ICJ and have committed to accepting the Court’s judgment as final and binding. They have also agreed to abide by any provisional measures the Court may order to prevent further escalation of the conflict. Several countries and international organizations have expressed support for the peaceful resolution of the dispute through the ICJ. The United Nations, the International Maritime Organization, and various human rights groups have offered to provide technical assistance and observers to ensure transparency and compliance with international law. The United Nations Secretary-General stated, "The peaceful resolution of disputes through international legal mechanisms is essential for maintaining global stability and upholding the rule of law." RELIEFS SOUGHT The Republic of Artavia requests the Court to adjudge and declare that: *. The Seago Vortex falls under the sovereign control of Artavia, and the unilateral declaration of an exclusive economic zone (EEZ) by Artavia around the Seago Vortex is consistent with international law. *. Belem must cease all unlawful fishing and mineral extraction activities in the waters surrounding the Seago Vortex and respect Artavia's sovereign rights over its maritime zones. *. Belem must compensate Artavia for the environmental damage caused by its activities in the Seago Vortex, including the costs of restoration and preventive measures. *. Belem must respect the rights of Artavian citizens, ensuring non-discrimination and protection against unlawful detention and harassment in the disputed areas. The State of Belem requests the Court to adjudge and declare that: *. The Seago Vortex falls under the sovereign control of Belem, and the unilateral declaration of an EEZ by Artavia is a violation of the NSRO treaty and international law. *. Artavia must cease its unlawful exploitation of resources in the Seago Vortex and dismantle any installations established in violation of international agreements. * *. Artavia must compensate Belem for the economic losses suffered due to the disruption of Belemese fishing and mineral extraction activities, including lost revenue and costs incurred. *. Artavia must respect the rights of Belemese citizens, ensuring their safety, freedom from unlawful detention, and protection against discriminatory practices in the region. * ANNEXURES Annex A: Selected Articles of the North Sea Regional Organization (NSRO) Treaty Preamble The member states of the North Sea Regional Organization (NSRO), recognizing the importance of regional cooperation, environmental protection, and peaceful resolution of disputes, agree to the following principles and provisions: Article *: Establishment of the NSRO The North Sea Regional Organization is hereby established to promote cooperation among member states in the North Sea region. Article *: Maritime Boundary Disputes Member states agree to submit any disputes regarding maritime boundaries to the International Court of Justice (ICJ) for binding resolution. Article *: Environmental Protection Member states commit to sustainable resource extraction practices and to protecting the marine environment within their jurisdiction. This includes adhering to international environmental standards and conducting environmental impact assessments for any major projects in the North Sea region. Article *: Compromissory Clause Any dispute arising between member states concerning the interpretation or application of this treaty shall be submitted to the ICJ for resolution, and the decision of the Court shall be final and binding. * Annex B: Documentation of Human Rights Violation Reports Report by Amnesty International Title: Human Rights Violations in Belem: An Investigative Report Date: March * Overview: This report presents a comprehensive investigation into the human rights abuses committed by the administration of General Hugo Santos in Belem from * to *. The findings highlight severe violations including extrajudicial killings, torture, and arbitrary detention. Key Findings: Extrajudicial Killings: The Solara Massacre is one of the most egregious incidents, where military forces opened fire on a peaceful protest on April *, *, resulting in the death of * civilians. Eyewitness accounts and forensic evidence corroborate the use of excessive and lethal force by government troops. Torture and Arbitrary Detention: The report documents the existence of secret detention centers where political prisoners were held without trial. These facilities were characterized by overcrowding, lack of basic amenities, and inhumane conditions. A notable case is that of Elena Marquez, a political activist who was subjected to electric shocks and waterboarding, as detailed in her harrowing testimony of physical and psychological abuse. Enforced Disappearances: Patterns of enforced disappearances involved abductions carried out by military personnel, often under the cover of night. The victims, many of whom were political dissidents, were never seen again, leaving families without any information on their fate. International Response: In response to these atrocities, the United Nations, United States, and European Union imposed targeted sanctions on key figures within Santos' regime. International NGOs provided humanitarian aid to support survivors and the families of the disappeared. The international community has repeatedly called for accountability and justice for the victims of these human rights violations. Report by Human Rights Watch Title: Systematic Abuses under General Santos: A Human Rights Watch Report Date: July * Overview: This report by Human Rights Watch delves into the systematic nature of human rights abuses perpetrated under General Hugo Santos' rule, underscoring the complicity of military and police forces in these violations. Key Findings: Legal Framework and Abuses: The administration's use of emergency decrees effectively suspended civil liberties, granting the military sweeping powers that led to arbitrary arrests and indefinite detention of political opponents. Military tribunals conducted secret trials devoid of due process, resulting in severe penalties. * Case Studies: Luis Ortega, a labor union leader, was arrested in November *. He was subjected to severe torture and subsequently sentenced to life imprisonment by a military tribunal. Similarly, journalist Isabella Fernandez was detained in January *, held in solitary confinement for 18 months, and endured both physical and psychological torture. International Reactions: The international community responded with targeted sanctions against those responsible for the abuses, which significantly impacted the Belemese economy. Diplomatic condemnations from various governments and offers of asylum for victims underscored the global denunciation of Santos' regime. United Nations Human Rights Council Report Title: Human Rights Situation in Belem: Report of the United Nations Human Rights Council Date: December * Overview: This authoritative report by the UNHRC details the extensive human rights violations committed under General Santos' administration, focusing on extrajudicial killings, torture, and enforced disappearances. Key Findings: Extrajudicial Killings: The report documents hundreds of cases of extrajudicial killings, with many more suspected. These killings primarily targeted political opponents and civilians, creating an atmosphere of fear and repression. Torture and Ill-Treatment: Detainees were subjected to brutal methods of torture, including beatings, electric shocks, waterboarding, and prolonged isolation. Conditions in detention facilities were inhumane, with reports of severe overcrowding and lack of basic necessities. Arbitrary Detentions and Enforced Disappearances: The administration's practices included indefinite detention without trial and numerous cases of enforced disappearances. Political prisoners and civilians were abducted, with no information provided to their families regarding their whereabouts. Recommendations: The report urges the Belemese government to implement judicial reforms and establish mechanisms to investigate and prosecute those responsible for human rights abuses. It also calls on the international community to maintain pressure on the Santos administration and support efforts to bring perpetrators to justice. * Annex C: Statements of Recognition by International States of the Two Belem Governments Initial Recognition of General Santos (*-*): United Nations Statement: Date: November * Overview: The United Nations initially recognized General Santos' administration, citing his control over key government institutions and the capital. However, this recognition came with concerns about potential human rights abuses and a call for adherence to international standards. Key Points: *. Control Over Institutions: ○ General Santos' administration controlled major government institutions, including the military and police. *. International Relations: ○ Initial diplomatic relations were established with other countries recognizing Santos' government. *. Concerns and Caveats: ○ The statement included concerns about reports of human rights abuses and urged the new administration to adhere to international human rights standards. Statements from Major Powers: *. United States: Date: December * Overview: The U.S. State Department issued a statement recognizing General Santos' government, citing stability and control over key regions. The statement emphasized the importance of democratic processes and urged Santos to hold free elections. *. European Union: Date: January * Overview: The European Union recognized Santos' government but expressed strong reservations about the legitimacy of the coup. The EU called for immediate steps to restore democratic governance and respect for human rights. Shift in Recognition to Dr. Fernandez (*-*): United Nations Statement: Date: May * Overview: Following reports of widespread human rights abuses by General Santos' forces, the UN shifted its recognition to Dr. Fernandez, acknowledging her as the legitimate president of Belem. Key Points: *. Human Rights Violations: ○ Detailed reports of atrocities committed under Santos' regime prompted the shift in recognition. * *. Democratic Legitimacy: ○ Dr. Fernandez’s commitment to democratic principles and human rights was emphasized. *. International Support: ○ Increased international support for Dr. Fernandez, with many countries aligning their diplomatic stances accordingly. Statements from Major Powers: *. United States: Date: July * Overview: The U.S. officially switched recognition to Dr. Fernandez, condemning the human rights abuses of the Santos administration and supporting democratic governance. *. European Union: Date: September * Overview: The EU issued a formal recognition of Dr. Fernandez, along with sanctions against key figures in Santos’ administration for their involvement in human rights violations. Current Recognition Status (*): List of Countries Recognizing Dr. Fernandez: *. Artavia: Date: June * Overview: Artavia formally recognized Dr. Fernandez as the legitimate president of Belem and established diplomatic relations with her administration. *. Canada: Date: August * Overview: Canada recognized Dr. Fernandez and provided humanitarian aid to support the rebuilding efforts in southern Belem. *. Australia: Date: October * Overview: Australia switched recognition to Dr. Fernandez and offered technical assistance to support democratic governance and human rights initiatives. Diplomatic Notes: *. Artavia to Belem (Fernandez Administration): ○ Expresses support for Dr. Fernandez and outlines plans for bilateral cooperation in areas of economic development and environmental protection. *. Belem (Fernandez Administration) to International Community: ○ Appeals for international recognition and support, highlighting the commitment to democratic principles and human rights. *. Responses from Other States: ○ Various diplomatic notes from countries acknowledging Dr. Fernandez and offering assistance in different capacities. *

what are the disputes here with regards to seago vortex

how could the countries claim soverignity why is this question even asked when exclusive economic zone cannot be claimed by anyyone

so how should i frame the first issue like for The Seago Vortex falls under the sovereign control of Belem, and the unilateral declaration of an EEZ by Artavia is a violation of the NSRO treaty and international law.

now my question is how could artavia establish soverign contro over seago vortex when it is not in the trritoeial sea of aratvia instead in the exclusive economic zone

so when argueing in front pf ICJ could we go in contravantion of UNCLOS

so how to better frame the soverignity part

but how could sovereignty be included

by proving all these even when it falls in the exclusive economic zone will it fall under the sovereignty of aratavia

if it is not sovereignty then what could i argue

are there any scenarios where icj has declared a area in the exclusive economic zone to be a soverign part of some other country

*-ial-*-*.doc jsn IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION IN ITS COMMERCIAL DIVISION INTERIM APPLICATION (L) NO.* OF * IN COM IPR SUIT (L) NO.* OF * Arijit Singh …Applicant / Plaintiff Versus Codible Ventures LLP and Ors. …Defendants ---------- Hiren Kamod, Prem Khullar, Neha Iyer, Vaibhav Keni and Priyanka Joshi i/b. Legasis Partners for the Applicant / Plaintiff. ---------- CORAM : R.I. CHAGLA J. DATE : 26TH JULY, *. ORDER : *. At the outset, Mr. Kamod, Ld. Advocate for the Plaintiff, tendered a draft amendment seeking to make some corrections to the Plaint, as more particularly set out in the draft amendment. In the interest of justice, the amendment is allowed. The draft amendment is taken on record and marked as ‘X’ for identification. Reverification is dispensed with. The amendments should be carried out within two weeks from the */* JITENDRA SHANKAR NIJASURE Digitally signed by JITENDRA SHANKAR NIJASURE Date: *.*.* *:*:* +* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc date when this order is made available. *. Mr. Kamod seeks to move without notice to the Defendants for the reasons set out in paragraph * of the Plaint. I find that sufficient averments and disclosures are made in the Plaint to sustain the ex-parte application. *. In the present suit, the Plaintiff is seeking protection of his personality rights viz. his own name, voice, signatures, photograph, image, caricature, likeness, persona, and various other attributes of his personality against unauthorized / unlicensed commercial exploitation, misuse of all hues thereof. The suit also pertains to the violation of the Plaintiff’s moral rights in his performances conferred upon him by virtue of Section *-B of the Copyright Act, *. *. It is stated that the Plaintiff hails from a small town named Murshidabad, in West Bengal, and has had humble beginnings. It is stated that the Plaintiff had immense passion for music from a very young age, leading to his journey from being a contestant on a musical reality TV show "Fame Gurukul", to a celebrated playback singer today. It is stated that today, the Plaintiff is one of the most celebrated, acclaimed and successful singers / artists */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc in the world. It is stated that the Plaintiff is recognized as a cultural icon globally and has been acclaimed as one of the foremost singers worldwide. The Plaintiff’s music appeals to a broad audience, across various age groups and demographics. It is stated that the Plaintiff has emerged as the most sought-after playback singers in the Indian music industry. *. It is stated that the Plaintiff has achieved immense success, goodwill and reputation as a singer due to his notable contributions to the music industry in India as well as abroad. It is stated that the Plaintiff’s repertoire spans across romantic ballads, Sufi renditions, peppy party tracks, and everything in between. Some of the Plaintiff’s most notable songs, such as “Tum Hi Ho” from the movie “Aashiqui *”, “Channa Mereya” from the movie “Ae Dil Hai Mushkil”, “Raabta” from the movie “Agent Vinod”, “Kesariya” from the movie “Brahmastra” have become chart-toppers. A list of songs which have been sung by the Plaintiff is at Exhibit “A” to the Plaint. Screenshots / printouts from streaming platforms showing particulars of the videos / sound recordings forming part of the Plaintiff’s repertoire as available on various platforms are at Exhibit “A-*” */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc to the Plaint. Details as available online / Wikipedia page in respect of the Plaintiff’s career are at Exhibit “A-*” to the Plaint. A pen drive containing the Plaintiff’s voice recordings / songs / repertoire is at Exhibit “A-*” to the Plaint. *. It is stated that the Plaintiff, through his extraordinary contributions and accomplishments, has earned a tremendous reputation and widespread goodwill amongst the members of the general public and in the Indian music industry. It is stated that over the course of his extensive career spanning several years, he has earned tremendous popularity and fandom from both the industry and audiences alike and has also solidified his standing as a prominent figure in the music industry. Screenshots / extracts / pages of the Plaintiff’s social media accounts on platforms such as Instagram, Facebook, X (formerly known as Twitter) and YouTube are at Exhibit “B-*” to the Plaint. Printouts of various digital articles on the Plaintiff are at Exhibit “B” to the Plaint. Printouts of webpages from https://www.forbesindia.com/ showing the Plaintiff’s name amongst the list of celebrities on the Celebrity * list for the years *, * and * are at Exhibit “C” to the Plaint. */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc Printouts of digital articles covering the story of the Plaintiff topping the charts on the music platform “Spotify” are at Exhibit “C-*” to the Plaint. Printouts of webpages from https://www.concertarchives.org/bands/ showing the list of tours and concerts done by the Plaintiff are at Exhibit “C-*” to the Plaint. A list of awards won by the Plaintiff is at Exhibit “D” to the Plaint. Screenshots / pages / articles available online evincing various awards won by the Plaintiff are at Exhibit “D-*” to the Plaint. Printouts of webpages from the website hosted on https://www.tatwamasi.info/ showing the activities of the Plaintiff’s Tatwamasi Foundation are at Exhibit “E” to the Plaint. *. It is stated that the protectable facets of the Plaintiff’s personality right and publicity rights, that are the subject matter of the present suit include the following: (a)the Plaintiff’s name; (b)the Plaintiff’s voice / vocal style and technique / vocal arrangements and interpretations; (c)the Plaintiff’s mannerism / manner of singing; (d) the Plaintiff’s image / photograph / caricature and his likeness; and */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc (e)the Plaintiff’s signature. At paragraphs * to * of the Plaint, the Plaintiff has described in great detail the manner in which the aforesaid facets of the Plaintiff’s personality rights have come to be exclusively associated with him. *. It is stated that as a well-known singer and celebrity, the Plaintiff holds the right to command and control the use of his personality traits since the same form part of his exclusive Personality Rights and Publicity Rights. It is stated that the misappropriation of any attribute of the Plaintiff’s personality traits without his express permission for a commercial purpose is liable to be restrained not only on the basis of the publicity rights namely the exclusive right to commercially exploit one’s personality but also on the basis of the tort of dilution, more particularly, tarnishment. It is further stated that any unauthorized distortion, mutilation, or other modification, or dissemination of the Plaintiff’s performances / voice or video recordings thereof, causing prejudice/harm to his reputation, would amount to a violation of the Plaintiff’s moral rights in his performances under Sections *-B of the Copyright Act, *. */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc *. According to the Plaintiff, the infringing activities of the Defendants that necessitated the filing of the present Suit are as under: A. Artificial Intelligence (AI) models / tools to synthesize artificial sound recordings of the Plaintiff’s voice (i) Defendant Nos. * to * are Artificial Intelligence platforms and / or their owners / founders / managers / operators as also Promoters that utilize sophisticated algorithms to create audio and visual content inter-alia mimicking/reproducing the features, such as the Plaintiff’s name, voice, mannerism / manner of singing, photograph, image, likeness, persona, and other attributes of his personality. It is stated that the Defendants Nos. * to * are deliberately using the Plaintiff’s personality traits to ride upon the Plaintiff’s goodwill and reputation. (ii) Defendant No.* operates an AI platform which allows conversion of any speech or voice recording or audio file inter-alia into the Plaintiff’s voice by using Real Voice Cloning (RVC) method. It is stated that a data set consisting of * songs from the Plaintiff’s repertoire are */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc unauthorizedly uploaded onto the AI Platform of Defendant No. * for the purposes of enabling any person to convert any text / speech / voice recording / audio file to the Plaintiff’s AI voice version. It is stated that one of the founders of the Defendant No. * has uploaded a video on the Defendant No. *’s social media channel on YouTube, wherein he is promoting / advertising a step wise guideline for unauthorized conversion of any text or speech or voice recording or audio file inter-alia into the Plaintiff’s voice by using the AI platform of Defendant No.*. In this Impugned Video *, the audience / members of the public are urged to use the steps demonstrated in the video to convert their own voice and / or any sound recording and / or song of their choice to the voice of their desired celebrity including inter alia the Plaintiff by using the platform of Defendant No.*. A copy of the Impugned Video * using the Plaintiff’s personality traits as uploaded by the Defendant No. * on its YouTube channel is filed in a pen-drive annexed as Exhibit “H” to the Plaint. In the Impugned Video * uploaded on a third party’s channel on YouTube (as more particularly provided at paragraph *(I)(vii) of the Plaint), the said */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc founder of the Defendant No. * once again demonstrates, promotes and advertises a stepwise guideline as mentioned for the Impugned Video * to unauthorizedly convert text, speech, sound recordings and / or songs to the Plaintiff’s voice by using the AI platform of Defendant No.*. The relevant averments in respect of Defendant Nos. * to * are at paragraphs *(I)(i) to *(I)(x) of the Plaint. The documents, screenshots and videos in support thereof are at Exhibits “G” to “K-*” to the Plaint. (iii) It is stated that the Defendant No. *, is an AI platform operated through the website, i.e., www.jammable.com (formerly www.voicify.ai) , for creating music using AI models of well-known singers / celebrity, etc. and appears to be founded by the Defendant No. *. It is stated that AI Voice Models with the Plaintiff’s name and photographs have been created on the website of the Defendant No. *, which can be accessed at https://www.jammable.com/models?q=arijit%20singh (formerly on www.voicify.ai). On this website, by providing any YouTube link or audio file, the Defendant No. *’s */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc website converts it to the Plaintiff’s AI voice and results / output. The Impugned Video * evincing the above is stored electronically in a pen-drive filed along with the Plaint at Exhibit “M”. Screenshots from the website i.e. www.jammable.com are at Exhibit “M” to the Plaint. (iv) It is stated that the Defendant No. * operates the AI platforms through the websites i.e., www.topmediai.com and https://filme.imyfone.com as per the contact us pages at https://www.topmediai.com/contact-us/ and https://www.imyfone.com/company/contact-us/, respectively. It is stated that on the website www.topmediai.com, there is a blog post / article on how to use their portal for text / speech / voice conversion to Plaintiff’s voice, which can be found at https://www.topmediai.com/text-speaker/arijit-singhvoice/. It is stated that apart from this blog post, the said website also directs the user to https://www.topmediai.com/text-to-speech/, where any text/ speech or voice can be converted into the Plaintiff’s AI voice. Screenshots from the website, i.e., */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc https://www.topmediai.com/text-to-speech/ and a video of the screen recording from the said website in a pen drive, evincing the above are at Exhibit “O” to the Plaint. (v) It is stated that Defendant No. *’s website https://filme.imyfone.com, has a page on how to convert text or speech / voice to Plaintiff’s AI voice which can be found at https://filme.imyfone.com/voice-change/arijitsingh-voice/. It is stated that apart from this page, the said website also directs the user to AI platforms i.e., voxbox and magic mic, where any text/ speech or voice can be converted into the Plaintiff’s AI voice. Screenshots of the website, i.e., https://filme.imyfone.com are at Exhibit “P” to the Plaint Sand screenshots from the page https://filme.imyfone.com/voice-change/arijit-singh-voice/ and a video of the screen recording from the said website in a pen drive are at Exhibit “P-*” to the Plaint. (vi) It is stated that the Defendant No. * is a company which inter-alia produces music and conducts modules / courses and uses AI tools for the same such as Defendant No. *’s portal, for creating music using AI models of well-known */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc singers / celebrity, etc. It is stated that the Impugned Video * uploaded on the Defendant No. *’s YouTube channel “Basslila” provides a tutorial for members of the public to convert text or speech / voice to Plaintiff’s AI voice and unauthorizedly uses deepfake and face morphing technology to create the Impugned Video * which uses, imitates and misappropriates for commercial gain, the Plaintiff’s name, voice, mannerism / manner of singing, image, likeness, persona, without the Plaintiff’s consent. An electronic copy of the Impugned Video * is stored in a pendrive filed at Exhibit “Q” to the Plaint. Printouts of other relevant webpages are at Exhibits “Q-*” to “Q-*” to the Plaint. B. Falsely representing an association with the Plaintiff (i) My attention is drawn to the averments in respect of the Defendant No. * which are at paragraph *(V)(i) of the Plaint and documents in support thereof at Exhibit “R” to the Plaint. It is stated that the Defendant No. * is a restaurant / pub which, as it appears, hosted an event in Bengaluru, Karnataka by unauthorizedly using for */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc commercial gain, the Plaintiff’s name and image. (ii) My attention is then drawn to the averments in respect of the Defendant No. * which are at paragraph *(IX)(i) of the Plaint and documents in support thereof at Exhibit “V” to the Plaint. It is stated that the Defendant No. * invited its users to sign up for a music event taking place in a virtual reality city hosted the website www.maicity.io. Upon signing up for the Defendant No. *’s event, the name and image / likeness of the Plaintiff was broadcasted / advertised / displayed to users so as to misrepresent to such users that the Plaintiff would be performing at Defendant No. *’s music event and / or that the Plaintiff had endorsed the Defendant No. *’s music event. C. Sale of Merchandise bearing the Plaintiff’s name, image, likeness and caricature (i) Mr. Kamod draws my attention to the averments in respect of the Defendant Nos. * to * which are at paragraph *(VII)(i) to (xi) of the Plaint and documents in support thereof at Exhibits “T” to “T-*” to the Plaint. It is stated that the Defendant Nos. * to * are commercially */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc exploiting the Plaintiff’s publicity rights, goodwill and reputation i.e. by advertising, promoting and offering for sale various merchandise such as posters, caricatures, portraits, t-shirts / clothing, framed photographs, guitar tabs, face-masks, phone cases, pillows, bottles, hoodies, sweatshirts, greeting cards, mugs, pins, magnets, spiral notebook, tote bags and zipper pouches bearing the Plaintiff’s name, image, photograph and / or likeness on various e-commerce websites / platforms viz. www.amazon.in, www.flipkart.com, www.desertcart.ae, www.kreateworld.in, www.thebong.in, www.prints4u.net, www.swagshirts99.com, www.meesho.com and www.redbubble.com. D. Platforms to create, store, search for and share Graphic Interchange Format files (GIFs) in respect of the Plaintiff (i) My attention is drawn to the averments in respect of the Defendant Nos. * and * at paragraph *(VIII) of the Plaint and documents in support thereof at Exhibits “U” to “U-*” to the Plaint. It is stated that the Defendant Nos. * and * are allowing their users / members of the general */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc public to create, store, search for and share GIFs comprising of short video recordings of the Plaintiff’s performances which also exploit the Plaintiff’s image, likeness and persona. It is stated that the Defendant Nos. * and * are unauthorizedly commercially exploiting the Plaintiff’s name, image, photograph / caricature, likeness, goodwill and reputation to make undue profits for themselves. Further, the unauthorised and uncontrolled dissemination and use of the GIFs bearing the Plaintiff’s image, likeness and persona through the Defendant Nos. * and *’s platforms has subjected the Plaintiff to ridicule, embarrassment and humiliation thereby prejudicially affecting his reputation. E. Infringing domain names (i) It is stated that certain unknown entities have registered the domain names arijitsingh.com and arijitsingh.in containing the whole of the Plaintiff’s name. It is stated that upon accessing the website hosted on arijitsingh.com, the webpage redirects to https://goid.com/app/home which appears to be a third-party website. There is no */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc website available on arijitsingh.in. Printouts from Whois showing the particulars of the domain names arijitsingh.com and arijitsingh.in are at Exhibit W to the Plaint which show that Defendant Nos. */* and * are the Registrar of the said domain names. *. It is stated that the Defendant Nos.*/* are the registrars of www.100xengineers.com and arijitsingh.com, Defendant No. * is the registrar of www.jammable.com (formerly www.voicify.ai) , Defendant No. * is the registrar of www.topmediai.com, www.filme.imyfone.com, and www.huggingface.co, Defendant No. * is the registrar of arijitsingh.in. and Defendant No. * is the registrar of www.audimee.com. *. It is stated that the Defendant Nos. * is the owner / operator of the cloud data storage platform hosted on the domain name www.drive.google.com, the website hosted on www.docs.google.com and the video streaming platform hosted on www.youtube.com used by the Defendant Nos. *, * and * to store and share their files / data and the Impugned Videos. It is stated that the Defendant Nos. * to * are the owners of the ecommerce platforms hosted on www.amazon.in, */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc www.flipkart.com, www.meesho.com, and www.redbubble.com, respectively, on which the Defendant Nos. * to * are listing their impugned goods bearing the Plaintiff’s name / image / photograph / likeness / caricature. For the purposes of the present suit, the reliefs sought by the Plaintiff against these Defendant Nos. * to * are limited to disclosure of the particulars of the Defendant Nos. * to *, * and *, and take down / removal of the infringing links / listings on their respective platforms. *. Mr. Kamod submits that the aforesaid instances of violation of the Plaintiff’s personality rights are not exhaustive and that in addition to the above, there are several entities / persons who are operating in a clandestine manner without a clear disclosure of their names, address and other details. He submits that the Defendants whose details are available with the Plaintiff are being impleaded in their named capacity, while the Defendants who have taken steps to ensure that their details are not freely available to the public, are being impleaded as Defendant No. * viz.“Ashok Kumar” or “John Doe”. He further submits that at this ex-parte stage, the Plaintiff is not pressing for any reliefs against */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc the Defendant No. *. *. Mr. Kamod further submits that the Defendant Nos.* to * appear to be in the business of providing means and tools to their customers to unauthorizedly create AI generated voice models of celebrities and popular fictional characters. He submits that the Defendant Nos. *, * to * are unauthorizedly commercially exploiting the Plaintiff’s personality traits namely, his name, image, photograph / caricature and likeness on various merchandise. He submits that these Defendants are misusing and exploiting the Plaintiff’s personality traits for personal and commercial gain at the expense of the Plaintiff’s rights. He submits that permitting the Defendants to continue exploit / violate the Plaintiff’s personality / publicity rights, without Plaintiff’s consent also jeopardizes the Plaintiff’s career as a performer / singer and his status of a celebrity. He submits that in so far as acts of Defendant Nos.*,* and * are concerned, the act of creating and disseminating videos (by using the name, photograph etc. of the Plaintiff) that instruct individuals on how to use unauthorized AI models to replicate a celebrity's voice such as Plaintiff without his consent cannot be shielded under the right of freedom of speech and expression. He submits that */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc unless reliefs as prayed for are granted, grave and irreparable loss and injury will be caused to the Plaintiff, and monetary compensation will not be an adequate relief. *. In support of his submissions, Mr. Kamod relied upon the following decisions: a. Karan Johar (Also known as Rahul Kumar Johar) v. Indian Pride Advisory Pvt. Ltd. & Ors., Order dated 13th June * in Interim Application (L) No.* of * in Commercial IPR Suit (L) No.* of *, b. Anil Kapoor v. Simply Life India, * SCC OnLine Del *, c. Amitabh Bachchan v. Rajat Nagi, (*) * HCC (Del) *, d. D.M. Entertainment (P) Ltd. v. Baby Gift House, * SCC OnLine Del *, and e. Applause Entertainment Private Limited v. Meta Platforms Inc. and others, Order dated 13th June * in Interim Application (L) No.* of * in Commercial IPR Suit (L) No.* of *. *. I have heard Mr. Kamod at length, and I have perused the */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc documents on record. I have also seen some of the videos / recordings stored on the per-drive annexed along with the Plaint. Prima facie, I am convinced that the documents on record establish that the Plaintiff in a notable singer / performer in India who has gained immense goodwill and reputation over the course of a very successful career and has acquired a celebrity status in India. *. It is now well-settled that celebrities are entitled to protection of the facets of their personality such as their name, images, likeness, voice, signature, etc. against unauthorized commercial exploitation by third parties. Recently, this Court in Karan Johar (Also known as Rahul Kumar Johar) v. Indian Pride Advisory Pvt. Ltd. & Ors. (supra) has held that personality / publicity rights are vested in celebrities and the unauthorized use of the name or other persona attributes of celebrities would amount to violation of their valuable personality rights and right to publicity. In this regard it would also be relevant to consider the following observations of the Delhi High Court in Anil Kapoor v. Simply Life India, * SCC OnLine Del *: “ * . The celebrity's right of endorsement would in fact be a major source of livelihood for the celebrity, which */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc cannot be destroyed completely by permitting unlawful dissemination and sale of merchandise such as t-shirts, magnets, key chains, cups, stickers, masks, etc. bearing the face or attributes of their persona on it without their lawful authorisation. *. Moreover, any form of misuse or commercial use of a celebrity's name, voice, persona, likeness has also been disapproved by the Supreme Court in the seminal judgment of R. Rajagopal v. State of T.N., (*) * SCC *, famously called as the ‘Auto Shankar case’. The relevant extracts of the same are set out below: “*. The right to privacy as an independent and distinctive concept originated in the field of Tort law, under which a new cause of action for damages resulting from unlawful invasion of privacy was recognised. This right has two aspects which are but two faces of the same coin — (*) the general law of privacy which affords a tort action for damages resulting from an unlawful invasion of privacy and (*) the constitutional recognition given to the right to privacy which protects personal privacy against unlawful governmental invasion. The first aspect of this right must be said to have been violated where, for example, a person's name or likeness is used, without his consent, for advertising — or non-advertising — purposes or for that matter, his life story is written — whether laudatory or otherwise — and published without his consent as explained hereinafter […] ….. *. We may now summarise the broad principles flowing from the above discussion: (*) The right to privacy is implicit in the right to life and liberty guaranteed to the citizens of this country by Article *. It is a “right to be let alone”. A citizen has a right */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc to safeguard the privacy of his own, his family, marriage, procreation, motherhood, child-bearing and education among other matters. None can publish anything concerning the above matters without his consent — whether truthful or otherwise and whether laudatory or critical. If he does so, he would be violating the right to privacy of the person concerned and would be liable in an action for damages. Position may, however, be different, if a person voluntarily thrusts himself into controversy or voluntarily invites or raises a controversy. (*) The rule aforesaid is subject to the exception, that any publication concerning the aforesaid aspects becomes unobjectionable if such publication is based upon public records including court records. This is for the reason that once a matter becomes a matter of public record, the right to privacy no longer subsists and it becomes a legitimate subject for comment by press and media among others. We are, however, of the opinion that in the interests of decency [Article *(*)] an exception must be carved out to this rule, viz., a female who is the victim of a sexual assault, kidnap, abduction or a like offence should not further be subjected to the indignity of her name and the incident being publicised in press/media. (*)……..” *. The technological tools that are now freely available make it possible for any illegal and unauthorised user to use, produce or imitate any celebrity's persona, by using any tools including Artificial Intelligence. The celebrity enjoys the right of privacy, and does not wish that his or her image, voice, likeness is portrayed in a dark or grim manner, as portrayed on the porn websites. Moreover, the Plaintiff's image is being morphed along with other */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc actresses in videos and images generated in a manner, which are not merely offensive or derogatory to the Plaintiff, but also to such other third-party celebrities and actresses. * . The Court cannot turn a blind eye to such misuse of a personality's name and other elements of his persona. Dilution, tarnishment, blurring are all actionable torts which the Plaintiff would have to be protected against. * . Even the domain names that have been registered are just being squatted upon, and there can be no reason why the same could be allowed to be squatted upon. The creation of ringtones and GIF images for commercial gains would also be a complete misuse of Plaintiff's rights. * . Under these circumstances, this Court has no doubt in holding that the Plaintiff's name, likeness, image, persona, etc., deserves to be protected, not only for Plaintiff's own sake but also for the sake of his family and friends who would not like to see his image, name and other elements being misused, especially for such tarnishing and negative use. *. The present case shows how elements of intellectual property that protect the attributes of an individual, in fact have other dimensions including rights protected by the Constitution of India. (emphasis is mine) *. In view of the aforesaid, prima facie, I am of the view that the Plaintiff’s personality traits and/or parts thereof, including the Plaintiff’s name, voice, photograph / caricature, image, likeness, persona, and other attributes of his personality are protectable elements of the Plaintiff’s personality rights and right to publicity. */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc *. It is a settled proposition of law that in an action for protecting personality rights and right to publicity, establishing the celebrity status of the plaintiff is only the primary ingredient. Additionally, it must be established that the plaintiff is identifiable from the defendant’s unauthorized use and that such use by the defendant is for commercial gain. In the present Suit, prima facie, the record shows that in the course of their impugned activities Defendant Nos. * to *, * to *, * and * are unauthorizedly using the Plaintiff’s personality traits such as name, image, likeness, etc. and that the Plaintiff can be specifically identified during such use. It also appears that such illegal exploitation of the Plaintiff’s personality rights and right to publicity by the Defendant Nos. * to *, * to *, * and * is for commercial and personal gain. Pertinently, all this is being done by these Defendants without any permission or authorization of the Plaintiff. Making AI tools available that enable the conversion of any voice into that of a celebrity without his/her permission constitutes a violation of the celebrity's personality rights. Such tools facilitate unauthorized appropriation and manipulation of a celebrity's voice, which is a key component of their personal identity and public persona. */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc This form of 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. *. What shocks the conscience of this Court is the manner in which celebrities, particularly performers such as the present Plaintiff are vulnerable to being targeted by unauthorized generative AI content such as that of some of the Defendants herein. These Defendants are attracting visitors / drawing traffic to their websites and/or AI platforms by capitalizing on the Plaintiff’s popularity and reputation, thereby subjecting the Plaintiff personality rights to potential abuse. These Defendants are emboldening internet users to create counterfeit sound recordings and videos that misuse the Plaintiff’s character and identity. In my view, creation of new audio or video content / songs / videos in the Plaintiff’s AI name / voice, photograph, image, likeness and persona without his consent and commercially using the same could potentially jeopardize the Plaintiff’s career / livelihood. Additionally, allowing the Defendants to continue using the Plaintiff’s name, voice, likeness */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc etc. in the form of an AI content, without consent of the Plaintiff, not only risks severe economic harm to the Plaintiff’s life/career, but also leaves room for opportunities for misutilization of such tools by unscrupulous individuals for nefarious purposes. *. Further, there cannot be any doubt that the advertisement, promotion and sale of merchandise such as posters, caricatures, portraits, t-shirts / clothing, framed photographs, guitar tabs, face-masks, etc. bearing / exploiting the Plaintiff’s personality traits as done by the Defendant Nos. * to *, without any permission from the Plaintiff, is in violation of the Plaintiff’s personality rights and right of publicity. Moreover, in the present case, the Plaintiff has specifically pleaded that he has made a conscious personal choice to refrain from any kind of brand endorsement or gross commercialization of his personality traits for the past several years. *. In the context of freedom and speech and expression, I agree with the submission of Mr. Kamod that even though such freedom allows for critique and commentary, it does not grant the license to exploit a celebrity's persona for commercial gain. In these circumstances, this Court is inclined to protect the */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc Plaintiff against any wrongful exploitation of his personality rights and right to publicity. *. In view of the aforesaid and considering the averments made paragraphs * to * and * of the Plaint, I am of the prima facie view that the Plaintiff has made out a strong case for the grant of ad-interim injunction, which may also operate as a dynamic injunction. Mr. Kamod’s reliance on the judgment of this Court in Applause Entertainment Private Limited v. Meta Platforms Inc. and others (supra) is apposite. The balance of convenience is in favour of the Plaintiff and against the Defendant. Unless the reliefs as prayed for are granted, the Plaintiff will suffer irreparable injury which cannot be compensated in terms of money. *. Mr. Kamod submits that at this ex-parte stage, the Plaintiff is only pressing for reliefs in terms of prayer clause (a), (d), (e), (f) and (g) of the captioned Interim Application and that the Plaintiff will press for further ad-interim reliefs in respect of the remaining prayer clauses at a later stage, after giving notice to the Defendants. */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc *. According to me, in view of what is stated hereinabove and in paragraph * of the Plaint, giving notice to the Defendants would defeat the purpose of the Plaintiff’s present application. In these circumstances, there shall be an ex-parte ad-interim order in terms of prayer clauses (a), (d), (e), (f) and (g) of the captioned Interim Application, except the portion in red brackets and modifications / clarifications hereinbelow. The extracted prayer clauses are as under: “(a) that pending the hearing and final disposal of the suit, the Defendant Nos. * to *, * and *, by themselves, their partners, proprietors, directors, owners, developers, servants, subordinates, representatives, employees, suppliers, affiliates, agents, stockists, distributors, dealers, subsidiaries, franchisees, licensees, assigns, predecessors and / or all persons / entity claiming through them be restrained by a temporary order of injunction from violating the Personality Rights and / or Publicity Rights of the Plaintiff by utilizing and/or in any manner, directly or indirectly, using or exploiting or misappropriating the Plaintiff’s Personality Rights and / or Publicity Rights by the use of his (i) name “Arijit Singh”, (ii) voice / vocal style and technique / vocal arrangements and interpretations, (iii) mannerism / manner of singing, (iv) photograph, image or its likeness, (v) signature, persona, and / or any other attributes of his personality in any form, for any commercial and/or personal gain and/or otherwise by exploiting them in any manner whatsoever, without the Plaintiff’s consent and/or authorization, including but not limited to through the use of any technology including but not limited to (i) unauthorized use of any of the */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc Plaintiff’s personality traits in any form or media, including online platforms, publications, advertisements, promotional materials, merchandise, domain names, or any other commercial endeavor, (ii) creating or using artificial intelligence voice models, or voice conversion tool, synthesized voices or digital avatars, caricatures, that imitate or mimic or represent the Plaintiff or Plaintiff’s personality traits, and (iii) artificial intelligence, generative artificial intelligence, machine learning, deepfakes, face morphing and / or GIFs, or any of them, on any medium or formats including but not limited to the physical medium, the virtual medium such as websites, Metaverse, social media, etc; (d) that pending the hearing and final disposal of the suit, Defendant Nos. *, * and * be ordered and directed to remove or cancel or suspend the impugned domain names arijitsingh.com and arijitsingh.in, or in the alternative transfer the impugned domain names arijitsingh.com and arijitsingh.in to the name of the Plaintiff; (e) that pending the hearing and final disposal of the suit, the Defendant Nos. * to * be ordered and directed to take down / remove / delete / block access to / suspend all [infringing content that has been uploaded by the Defendants herein as well as] the infringing URLs identified by the Plaintiff in Exhibit X to the plaint; (f) that pending the hearing and final disposal of the suit, the Defendant Nos. * to * be ordered and directed to disclose all particulars of the Defendant Nos. * to *; (g) that pending the hearing and final disposal of the suit, the Defendant Nos. * to * be ordered and directed to disclose all particulars of the Registrant(s) of the impugned domain names www.100xengineers.com, www.jammable.com, */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc www.topmediai.com, www.filme.imyfone.com, and www.huggingface.co, “arijitsingh.com”, “arijitsingh.in” and “www.audimee.com” to the Plaintiff;” *. The aforesaid order / directions shall not operate against the Defendant No. * at this stage. *. In so far as aforesaid prayer clause (d) is concerned, it is clarified that at this stage, the Defendant Nos. *, * and * shall only lock / suspend the domain names arijitsingh.com and arijitsingh.in and they shall not permit any transfer thereof to third parties until the next date of hearing. On the next date, after giving notice to these Defendants, this Court shall consider the Plaintiff’s application to take over these domain names subject to payment of requisite charges. *. While there cannot possible be any reasonable justification for the blatant violation of the Plaintiff’s personality rights and right to publicity as aforesaid, I do not think that taking down the entire videos of the Defendant Nos. *, * and * on the following links is appropriate. A direction to these Defendants to simply remove or delete all the references to the Plaintiff’s name, image, voice, personality traits etc. in the said videos should suffice. Accordingly, in so far as the videos on the following links */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc (also reproduced in Exhibit “X” to the Plaint) are concerned, the Defendant Nos.*, * and * are directed to edit/delete/remove all references to the Plaintiff’s personality traits, including his name, voice, image, likeness, etc. from the said videos: a. https://www.youtube.com/watch?v=RJ0fgV-kXwI b. https://www.youtube.com/watch?v=4GmiiekhOak c. https://www.youtube.com/watch?v=6lhof7oKeU4 d. https://www.youtube.com/watch?v=Kni5mn9TFgU e. https://www.youtube.com/watch?v=0iGSNeU-tDY *. The Defendant Nos. * to * are directed to comply with the directions passed in terms of prayer clauses (f) and (g) of the Interim Application reproduced above, within two weeks from the date of service of this order. The Defendant Nos. * to * are directed to co-operate with the Plaintiff, its representatives and Advocates to provide the necessary details for the effective implementation of this order. *. Compliance of Order XXXIX Rule * CPC is also permitted by email considering the large number of Defendants, and the fact that most of the contact details may not be available. In so far as those Defendants for whom postal addresses are available, the */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: *-ial-*-*.doc Plaintiff shall also in addition do compliance by speed post service. The said compliance shall be done within two days of this order being made available. *. Liberty to the Defendants to apply for a variation or modification of this order after at least * clear working days’ notice to the Advocates of the Plaintiff. *. List the above Interim Application on 2nd September, * for further ad-interim reliefs. *. This order will continue till 3rd September, *. *. This order will be digitally signed by the Private Secretary / Personal Assistant of this Court. All concerned will act on production of a digitally signed copy of this order. [ R.I. CHAGLA J. ] */* ::: Uploaded on - */*/* ::: Downloaded on - */*/* *:*:* ::: summarise it

whta are the (*) Facts of the Case and Background of the Decision, (*) Issues Raised, (*) Decision and Ratio, (*) Analysis, (*) Impact on Indian IPR Law.

complete it

explain the Impact on Indian IPR Law in detail

make this into a single paragraph