Bridging the Digital Divide: A Comparative Analysis of Deepfake Regulation in India and the United States

Abstract

The rapid development of deepfake technology synthetic media created by artificial intelligence to convincingly imitate human appearance and behaviour poses a structural problem to the global legal order. Beyond being a mere advancement in disinformation, deepfakes represent a fundamental challenge to the epistemic trust upon which democratic, legal, and diplomatic processes rely. By enabling low-cost, high-impact deception, they exploit the grey zones of digital governance, complicating principles of cyber sovereignty and making it difficult to attribute wrongful acts in the digital sphere.