THE DISEMBODIED PLAINTIFF: CAN AVATARS AND AI AGENTS HAVE STANDING IN INDIAN COURTS?

This article has been written by Aayush Chhabriya, a law student at Symbiosis Law School, Hyderabad.

***This article has been selected for LegalOnus Law Journal (LLJ) Volume 1 Issue 9 2025

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Abstract The Apex Court of India has begun to make aggressive moves towards digitising the legal system under the direction of Chief Justice D.Y. Chandrachud. This action has made the judicial processes far more user-friendly and accessible. The use of artificial intelligence (AI) in legal proceedings has also been promoted and endorsed by former Chief Justice Sharad Bobde. Even yet, it is obvious that AI should support judges rather than take their place. The goal is to develop AI tools that are completely compliant with the law, free from prejudice and conjecture. AI is often called the fourth industrial revolution as it has the ability to change altogether the way people live, although will it be able to change how our courts and legal system works. In basic language, the paper looks at whether these “disembodied plaintiffs” who don’t exist in a physical form should be given a lawful acknowledgement in the courts of India. It starts by telling what avatars and AI agents are, how are they operating the digital spaces, and also how people interact in the virtual word by using them. It also takes into account useful strategies like “lifting the veil” to reveal more about the person behind the avatar. The paper also suggests that the law in India may require to evolve to handle these upcoming issues. It suggests two important steps, i.e. creating new laws and encouraging the courts to go through the existing laws in such a way that can then apply to these issues that are now emerging. In this world where the line between actual and virtual is now becoming opaque, the law must address the rights and responsibilities of digital beings. Keywords: Artificial Intelligence, Avatars, Disembodied Plaintiffs, Legal Personality

Introduction

As the people get into an increasingly digital world[1], the way they interact, work, and live I changing. From AI-powered help to virtual avatars in the metaverse, our online availability has now become more advanced and more real than ever before in the past. These new technologies being introduced are no longer a science fiction but they are part of ones daily live. Since our interaction change into the virtual space, therefore a important legal question arises that, whether these digital entities i.e. avatars and AI agents, can stand before the Indian court of law? In simple language, whether they can sue someone or be sued by someone?

This research paper explores whether the avatars and AI agents can have “locus standi” in the courts of India, which means whether the Indian law can treat them as “persons” who can be a part of the legal case. In easier language it means whether the person or entity has the ability to bring a case to the court. In India, locus Standi concept is rooted in the idea the person coming to the court must be affected directly to the matter. For example, if a person’s land is taken away from him unlawfully, then they have the right to take the matter to the court which is his legal rights and legal standing.

An exception to the usual rule is public interest litigation (PIL). In such cases, any concerned person can approach the court on behalf of others who are unable to do so themselves. This broader approach to who can file a case was clearly explained by the Supreme Court in the case of S.P. Gupta v. Union of India[2], where it allowed more flexibility in deciding who has the right to bring a case. Now, the important question arises that can something which is not human, like an AI or avatar, be given such standing?

Understanding AI Agents and Avatars

An artificial intelligence (AI) agent is a computer software designed to make judgements, learn from data, and engage in brief human-like interactions.  Examples of this in the real world include chatbots, Alexa, and Siri, which are all types of artificial intelligence agents.  Some of these are even able to conduct commerce, negotiate contracts, and produce music or art.

Avatars are digital or virtual representations of real people. It nearly seems like a person, yet it might also look like a cartoon character or a robot. Among other virtual worlds, they are mostly used in video games, internet platforms, and the metaverse. Both of these AI agents and the avatars can do actions that have legal effects i.e. like entering into agreements or causing harm. Therefore, whether the law should recognize them in same way it is done with the human acts is a question.

To ascertain whether AI agents and avatars could have legal standing in Indian courts, it is essential that we first understand what they are, how they operate and why they are such an interesting challenge for legal systems to grapple with[3]. Artificial Intelligence (AI) is a term used to describe the ability of a machine or software program to act with the same kind of intelligence as a human being. Such AI applications can run on different kinds of AI models: Narrow AI, AI applied to a particular task like face recognition or speech translation; General AI, would theoretically match or exceed human intelligence in kind of task matter; and Superintelligent AI, as of now, non-existent future AI which would exceed human intelligence in all aspect categories.

AI-Agent In a legal sense, AI is any combination of hardware and software whose purpose is to control or monitor the environment. These agents are capable of performing actions, making decisions, learning from success, and in some cases adapting their actions separate from humans. Algorithmic trading robots, diagnostic systems, self-driving cars, and AI-driven legal research assistants are just some examples[4]. They also raise thorny legal questions about who bears the responsibility for decision making, liability, and responsibility if they are involved in causing harm, particularly if little or no control is exercised by humans.

Avatars, though, are roots mainly in virtual culture — and, specifically, in virtual places such as video games, metaverse websites and online social media simulations. Graphical representations or digital surrogates of real-world users are avatars that represent them in these shared spaces[5]. But now, with the increasing AI (Artificial Intelligence) avatars, these avatar acts are not just mere puppets receiving human intervention, but also may contain conversational AI [20], decision-making and real-time interaction with other actors as well[6]. They can now speculate in cryptocurrency, contract in metaverses and ‘produce’ digital content, blurring the line between digital agent and legal person.

Technologically, AI avatars and agents are both powered by a combination of machine learning, natural language processing (NLP), artificial neural networks (ANN), and large language models (LLM) like GPT or BERT. Artificial intelligence (AI) systems analyse vast volumes of data to find trends and decide what to do. The proliferation of generative AI has made it possible to create avatars that can mimic human appearance, replicate emotions, or even capture a person’s voice or personality. This has resulted in a whole new set of legal issues, including deepfakes, defamation, personality rights, and data protection issues[7].

In addition to this, AI avatars are beginning to actually have the capability to do socially and economically valuable things. An avatar can for example hold non-fungible tokens (NFTs), purchase digital assets or perform governance tasks in decentralized autonomous organizations (DAOs). Legal systems worldwide are still struggling to determine whether such avatars should be considered as nothing more than instruments for their human users, or entities endowed with some elementary legal rights.

The only distinction that remains between AI agents/avatars and either corporate or deities being that of intention or sentience, however, respectively and distinctly. The corporate body and gods are served by agents and or boards of directors or ‘trustees’ and or “kardars’ legal entities, containing no moral compass or informed or conscious AI. But AI systems are already engaged in activities that would normally be the domain of a legal person, such as making contracts and shaping human action.

Legal Personality in Indian Law

As per the Indian law, a “legal person” is an entity which can have its own rights and duties, that not only includes humans but also companies, trusts, and even religious idols have been given the tag of legal personality.

• A company is a non-living entity but can own a property under its own name. It can also enter contracts, and can sue and can be sued which is covered under Companies Act, 2013.
• In Yogendra Nath Naskar v. Commissioner of Income Tax[8] case the Supreme Court of India accepted that Hindu idols could be treated as a separate legal person.
• In Salim v. State of Uttarakhand[9] case the river Ganga and Yamuna was declared to have its own different legal rights.

The above examples show that the idea of a “legal person” in India is flexible and vast as the courts have expanded it when needed. Therefore, it can be said that the AI agents and avatars too could be added under this umbrella. This can be explained with various points like[10]:

1. Few of the AI agents can take smart actions by themselves, like entering into contracts or making financial decisions. If the actions taken by them causes harm or create any obligations, there must be certain way to address this in law.
2. Certain people use these avatars to sell, buy or manage digital assets like the NFTs and virtual land. But if someone tries to steal or damage these properties the avatar should be able to seek legal protection.
3. Foreign countries have started talking about AI and legal personality. In 2017, the European Parliament has already suggested creating a form of “electronic personhood” for the advanced AI systems.
4. Giving some legal recognition to the AI agents and avatars make sense as some of them play a similar role like humans of managing money or forming contracts.

With the plus points, there are also some minus points to it like:

1. AI and avatars don’t have feelings, emotions, or moral judgment which the court generally expect from a legal person to understand what’s right and wrong.
2. If something which wrong is done by the AI, then who should be blamed is the question, whether the programmer, the user or the AI itself. The Indian laws don’t have any clear answers yet.
3. By allowing the AI agents and avatars to file the lawsuits would open the door to fake cases or scams which could then waste the time of the court and resources.
4. Indian courts and the legal system basically works on the idea of physical presence and real-world harm, virtual harm is still a grey area[11].

Juristic Personality and Standing in Indian Law: Substructure and Superstructure

The issue of legal standing of avatars / AI agents, before Indian courts, takes us naturally to the domain of the doctrine of juristic personality. Accustomed to English common law, Indians have long known that the capacity to act under law is not something to be hogged by human beings.

It simply provides for service of certain entities, not human beings, such as corporations, gods, rivers, and trusts, with duties or rights[12]. This supple model is invoked in the heart of the claim that a person of artificial intelligence would, in some identities, also be considered for such a status.

The reported case of Pramatha Nath Mullick v. Pradyumna Kumar Mullick[13], the onus to prove the property to be the ‘deity’s property’ rested not the plaintiffs but the defendants was placed on the deity. In the early case, perhaps for the first time the Indian judgment recognized the Journal of Constitutional Law possess a personality in law and; personality of the deity chose to act through the medium of the kardar can it also be made a party to an action, that is to say, can it sue and be sued?- The learned judge of the High Court marks the distinction drawn in the case to be the respect paid to the property of the Hindu deity and the individual property owner. In Ram Jankijee Deities v. State of Bihar[14], the Supreme Court of India restated this argument, stating once more that judicial personhood is an artificial legal construct intended to make it easier for social or cultural individuals to get justice and adjudication. The position in Mohd. High court in Salim v. State of Uttarakhand[15] ruled in favour of rivers Ganga and Yamuna as juridical person for environmental issues even though rivers are not sentient or agents.

The legal ground for these decisions is in representational legitimacy – the view that some non-living things can be considered legal persons for pragmatic purposes if someone can represent it. When it comes to the legal status of AI agents, it is a critical problem. If a non-person as an AI entity is able to do physical or legal harm, then there may be a good reason to have a legal framework in which a human is a proxy or guardian for that AI in court, as is the case for infants, imbeciles, or gods[16].

What is more, a change is also visible in the doctrine of locus standi under Indian law. Heretofore constrained to persons having a direct concern in a matter, this was extended by the public interest litigation (PIL) doctrine whereby citizens and even groups which are not part of the administration may approach courts in the names of others who were unable to do so themselves[17]. This is to say that standing is not always based on sentient experience, but is to be accorded when there is a strong legal or social concern for it.

The Indian law of companies also lays down this general principle. Although they are a product of art, they are full legal persons. Even as in Floating Services Ltd. V. MV San Francesco Di Paolo[18], the vessel has a similar form of quasi-legal personality in respect of admiralty claims. The justification is instrumental: legal persons are a judicial shortcut, rather than an ontological description limited to human beings.

But A.I. agents present a different set of challenges than those of idols or corporations. Unlike idols that are the focus of human idolatry, or corporations that are governed by boards, and the humans who serve on them, AI agents are typically at least partially autonomous. This makes determining blame or intent difficult. That being said, courts can also reconcile existing case law, like those involving idols or trusts, to impose potential liability on AI developers, users and owners.

This part illustrates that Indian law already possesses a comprehensive and flexible mechanism for according legal personality to non-human entities. The precedent is clearly, if idols can own property held in trust, and rivers can sue to protect their interest in preserving their flow, then having legally established AI agent standing through a formally licensed human representative isn’t even that much of a stretch.

How the concept AI agent and avatar emerged

A guy called Jerome Dewald[19], who was battling his own employment case in New York, shocked the judges on March 26, 2025[20], by appearing in court virtually and instead presenting a video of an AI-generated avatar making an argument on his behalf.

At first the judges thought it to be a normal video, but later they realised it wasn’t Dewald speaking, but a computer created avatar doing so. This avatar began with the basic courtroom greetings, but the judges stooped it asking for Dewald that it would have been better if the court was informed about it in prior of using AI instead of coming himself.

This case showed that how far AI is being pushed while also showing its limits. Using AI for legal research and drafting of documents is common among the people but letting it argue in courtrooms was very controversial. Legal expert said that just having an AI to speak for you wasn’t enough as if any argument went wrong the AI won’t be able to fix it. The real court arguments involved back and forth conversation with the judges, which the AI avatar can’t think on the spot or reply on expected questions like a human can.

This case showed the conflict between upcoming technology and traditional court rules. Courts may welcome AI tools that help lawyers, but it is not ready to replace human speakers in the courts. The court told Dewald that he had to argue his case in person, confirming that human presence is still essential in legal proceedings.

Also, in many Indian cases like Jaswinder Singh v. State of Punjab[21], the court said that the use of AI shouldn’t be completely prohibited in the legal area as it shows to be suitable for preliminary understanding and research work. The High Court of Punjab and Haryana[22] also used Chat GPT in a case to determine the jurisprudence of bail.

AI in the Global Context

On a global scale the legal status of the digital entities remains visible in the official reluctance of various international jurisdictions in keeping pace with technological development at the expense of established thresholds of legal personality. By delving into different legal frameworks on AI across the world, Indian jurisprudence can even further prepare to respond to changing. However, if people’s interests are at stake the Indian courts could consider AI related claims due to the liberal standing in PILs.

• The European Union On the Way to “Electronic Personhood”

In 2017 the European parliament’s committee on legal affairs laid the proposal for exploring “electronic personhood” for those sophisticated artificial intelligence systems particularly those which have autonomous decision-making capabilities. But for now, the “electronic personhood” is still a theory. And thinkers such as Joanna Bryson went so far as to suggest that bestowing personhood on AI could overcomplicate liabilities[23].

Thus, it can be stated that legal personality is not the same thing as, nor necessarily involves, such metaphysical personality or ethical notion of personhood[24]. On one we can see the legal personality as a kind of juridical status the law may attribute when it should feel disposed to pursue its own ends.

Here the European Union’s effusive debate around electronic personhood mirrors that of India relating to non- persons such as deities and rivers. In the same vein, the employment of a prudential method of narrow standing for AI-related cases, can assist in shaping regulative structures of the Indian jurisprudence. India presently models its data protection rules and policies on EU’s GDPR (General Data Protection Regulation) which indicates that it is possible for an AI framework to be a salvageable subset of a GDPR-type law. EU’s risk-based approach may also influence India to modify the dispositions such as Digital Personal Data Protection Act, 2023 and Information Technology Act, 2000 concerning judicial role of AI.

Overall, the global landscape in AI indicates that India needs to move cautiously by being creative in its judicial approach. ‘By adopting best practices from abroad while avoiding their mistakes with transparency, India can build a streamlined legal structure to keep pace with technology to secure justice in the increasingly AI-enabled future.

The issue of legal personhood for AI avatars and agents is not unique to Indian law. Around the globe, lawmakers and judges grapple with both the philosophies and logistics of AI personhood. Although no jurisdiction has conferred complete legal personhood to AI systems yet, there are a few cases and policy developments that provide comparative experiences for the Indian legal system to leverage.

• S Non-Human Standing is Unthinkable:

Here in the US, the courts have largely refused to consider the option of granting legal standing to anything that isn’t human, or at least human-like, even if it is sentient. The quintessential leading case cited is Naruto v. Slater[25] (the Ninth Circuit Court of Appeals held that a macaque monkey named Naruto did not have standing to bring a copyright infringement action under the Copyright Act). The court argued that the statute was not conferring rights on animals and placed a heavy reliance on clear legislative intent to confer legal personhood.

Naruto was using an animal, although its reasoning has been analogised to AI systems in academic and juristic writing on the basis that it has no legal agency, no moral reasoning nor intentionality. In other words, U.S. policy is one of conservatism and caution, you got to a get specific legislation, “spelling it the hell out” the personhood or standing of anything besides people.

Moreover, as per the U.S. copyright law, the Copyright Office has issued a statement, clarifying that works generated by AI alone (in the sense of no human author involved) are not protected by copyright[26]. This reflects a broader reluctance to grant legal status to the work of AIs, or to the programs themselves for that matter.

• The Symbolism that is Saudi Arabia without Substance

Saudi Arabia drew media attention in 2017 after it gave citizenship to an AI humanoid called Sophia. It represented the first case in which a state recognized the formal citizenship of a robot[27]. Still, the action was roundly condemned as symbolic instead of substantive—it lacked legislative basis for delineating the rights, duties, or obligations of Sophia as a citizen. Legal analysts viewed it as a publicity gimmick and not a genuine effort at re-legislating citizenship laws.

Sophia’s case must be mentioned here since it shows how legal personhood, symbolic or not, can be confusing and also controversial. It highlights the importance of any declaration of AI by law being combined with strict definitions, responsibility mechanisms, and enforceable processes.

Takeaway for India

Comparative analysis brings a range of interaction with AI legal status to light. The U.S. adheres to a classical human-centric model, and the EU is investigating function-based and liability-based hybrid models. Saudi Arabia has accelerated symbolically but currently legally has no bite. India, already acknowledging non-human legal persons such as rivers and idols, judiciously designed, contained legal standing for AI agents—human representation and accountability—can be doctrinally sound and pragmatically viable.

Room for Legal Recognition of Digital Agents

There is no legal provisions exist in India to recognize non- human entities such as AI agent, avatars etc., as legal entities. This leads to a number of obstacles in assigning difficulties and safeguarding rights.

Giving statutory recognition may be the middle path to facilitate the digital agents to transact within the regulatory periphery. Statutory recognition of digital units could include giving them legal personality though limited to the level of legal capacity meted to juristic persons to represent those organizations or humans, holding rights in particular contexts, or liabilities.

Systems of contracting automation that back assign to human principals are valid under Singapore’s Electronic Transactions Act, 2010. India can use such an analogy and it can define digital agents as “Software entities authorized to act on behalf of capable persons” under Section 11 of the Indian Contract Act, 1872.[28]

While the limited legal standing of AI agents and avatars is a matter of debate the fact that it is somewhat topical already means the grant would enshrine justice in digital interactions, align the laws and the legal framework with the technology and thus protect our digital assets. Although there is much scope statutorily in India for recognizing digital agents, the problems such as ethical hazard, liability inferences, and judicial competence cannot be overlooked.

Implication and Future Direction

The balanced perspective required to evolve regulatory frameworks might enable ethical governance of digital entities without undermining the judiciary. The following suggestions will help spell out the potential for digital entities to become involved in the Indian Judiciary:

• Standing does not require that the grant of standing in effect make one a full person. The procedural posture as with the filing of the suits, for some activities, such as for the varying kinds tasks, AI agents and avatars could be provided procedural standing without being treated as a juristic person. This would serve to restrict the standing of the digital entities.
• The meager procedural standing can be used as a way of managing cases and filing of motions and thereby reduce the workload of the judiciary.
• India can explore a model in which digital entities serve as intermediaries on behalf of humans or all types of juristic persons, akin to the guardians for rivers or gods. That would make it easier to accept the AI-related claims, without bestowing upon them full personhood.
• The Indian courts may experiment with subordinate courts AI assisted filings with proper supervision of humans; which can try reducing the risk.
• There should be a new dossier for regulation of AI in judiciary or new guidelines under the Information Technology Act, 2000 should be made for AI legal proceedings with restricted standing for AI and banning AI’s independent representation without adequate human supervision.
• To avoid mistake and prevent against fake AI generated precedent the AI training shall be given to the judges and to the court staff.
• To achieve global alignment, India may associate with other global partners like China, EU etc. It can be used to ground international standards for digital entities before the courts.

Conclusive Argument

Amid this fascinating confluence of law, technology and ethics comes the question of whether AI avatars and agents can be plaintiffs in Indian courts. Under Criminal Procedure Code, 1908 as well other laws in India, only “persons” can file suits i.e. natural persons or juristic persons.

Indian jurisprudence has proved to be flexible by conferring locus standi upon non-human entities such as rivers, animals and corporations but when it is a question of AI and Avatars, the exceptions are in the nature of above-mentioned problems which pertain no liability and sentite or clear legal status.

But the present resume of Indian judiciary encourages the AI to function as a tool and not an applicant. This is best exemplified by the increasing adoption and usage of AI enabled tools like SUVAS (for translations of judgements) and SUPAC (for management of cases).

Based on the above arguments, it can be identified how the requirement of the AI driven litigations became more essential with the pace of digital economy growth (e.g., metaverse transactions) The controversies which surround the locus standi grant make the matter more complex since risk of grant of standing to digital entities can be there, yet ignoring the issue is equally vexed. Granting use rights to AI actors and avatars may also result in an disparity, as AI does not have human weakness and sentinance. On the other hand, the rejection of the locus standi may lead to exclusion of meritorious claims.

The arguments held that if the corporations, deities, rivers etc who don’t have physical form can be given locus standi in the court on the ground that these have interests to protect, then, AI agents or Avatars — in spite of not having physical form — must be granted that status because these also represent the interests of their creators. In contrast, we can argue that the standing test in cases such as Animal Welfare Board of India v. A. Nagaraja (2014)[29] requires both demonstrable harm and legally protected interests or sentiance to meet the standard of the animal-victim test. The standing test in the aforementioned case may also apply to digital entities, but if those entities lack self-government and autocracy, then their lack of autonomy does not allow for the violation of interests that are distinct from those of their creators.

To the contrary, the Al may contribute to the democratization of representation in court for those indigent and who could not afford lawyers, though it would be unregulated and possibly worsening or discriminating in some cases. When digital personae are used without disclosure to the court it can also cause the court to be deceived as in Dewald case (2025) New York[30]. This type of treacheries could shake down the edifice of transparency on which the judicial system stands. Other problems may be an induced situation of if the suit against the Digital entities will be started and in case any nonsense or error occurs then on whom it will be devolved to the User, programmer or developers. Such uncertainty and serious lack of accountability could have the effect of undermining fairness and offending the principle of natural justice.

Nevertheless, despite some of these obstacles, AI has too much promise to be disregarded, potentially enabling the Indian judiciary to address the enormous backlog of unresolved cases and enhance the administration of justice, especially for the underprivileged groups. “By talking about what AI could be, we can figure out how to make it beneficial and establish some of the checks and balances including proper disclosure, ethical guidelines, human control, and government regulation.”

Conclusion

Thus far given how new the technological development issue is it seems that limited standing as a proxy could be possible, especially if it is seen in light of technological evolution and global precedents set and most importantly, the current regulatory discussions meant that it could possibly be explored. These suggestions can contribute towards the improvement of access to justice through addressing the core problems with inclusive reform and evidence-based policy that can be taken up by the judiciary in abiding by the constitutional mandate of equality and fairness.

To sum up in India AI assisted agents and avatars cannot be legally said to take decisions now because of the legal and ethical implications. But the expanding involvement of AI reminds us of the need to approach its rapid evolution of with even-handed innovation and responsibility.

[1] Srinivasan Sekaran, Employing Artificial Intelligence for Adjudication in Indian Courts, 17 ResearchGate, 409, 410 (2024)

[2] S.P Gupta v. Union of India, AIR 1982 SC 149

[3] Sai Dheeraj Dronadula & D. Vijaya Bhaskar, Impact of Artificial Intelligence on Legal Profession and Justice System, 6(2) Int’l J. L. Mgmt. & Hum. 1084 (2023),

[4] Akhil Raj, How Generative AI Can Help Address the Access to Justice Gap Through the Courts, SSRN (19^th June, 10:15) https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4683309

[5] Ben Chester Cheong, Avatars in the Metaverse: Potential Legal Issues and Remedies, 3 Int’l Cybersecur. L. Rev. 467–494 (2022), https://doi.org/10.1365/s43439-022-00056-9

[6]Ben Chester Cheong, The Rise of AI Avatars: Legal Personhood, Rights and Liabilities in an Evolving Metaverse, 2(4) J. Dig. Tech. & L. 857 (2024), https://doi.org/10.21202/jdtl.2024.42

[7] Hart Cohen, Digital Humanities in the Indian Rim Contemporary Scholarship in Australia and India (147) [(Hart Cohen 2024)]

[8] Yogendra Nath Naskar v. Commissioner of Income Tax, AIR 1969 SC 1089

[9] Mohd. Salim v. State of Uttarakhand, 2012 SCC OnLine Utt 558

[10] Medium, https://aiplusinfo.medium.com/ai-avatar-in-court-judges-response-disappoints-54281676c5e1, (last visited June 17, 2025)

[11] Anil Gore, India Courts of Law can benefit Immensely by Adopting Artificial Intelligence Methods for a Speedy and Accurate Justice, ResearchGate, (June 17, 2025, 9:05 PM), https://www.researchgate.net/publication/359178404_Indian_Courts_of_Law_can_Benefit_Immensely_by_Adopting_Artificial_Intelligence_Methods_for_a_Speedy_and_Accurate_Justice

[12] Supra Note 3

[13] Pramatha Nath Mullick v. Pradyumna Kumar Mullick, (1925) 52 IA 245.

[14] Ram Jankijee Deities v. State of Bihar, AIR 1999 SCC 2131

[15] Supra Note 9

[16] Shiromani Gurdwara Parbandhak Committee v. Som Nath Dass, (2000) 4 SCC 146

[17] Supra Note 2

[18] Floating Services Ltd. v. MV San Francesco Di Paolo, AIR 2000 Bom 34

[19] Lars Daniel, AI Avatars Replacing Human Lawyers In Court? Recent Cases Says Not So Fast, Forbes, (June 17, 2025, 10:17 PM), https://www.forbes.com/sites/larsdaniel/2025/04/08/ai-avatars-replacing-human-lawyers-in-court-recent-case-says-not-so-fast/

[20] Dewald v. Riegel, (2025) NY Slip OP 31937 (U)

[21] Jaswinder Singh v State of Punjab, 2024 SCC OnLine P&H 9523

[22] Majmudar & Partners, https://www.majmudarindia.com/wp-content/uploads/2023-09-25-AIUpdate.pdf, (last visited June 17, 2025)

[23] European Parliament, https://www.europarl.europa.eu/doceo/document/A-8-2017-0005_EN.html. (last visited June 19, 2025)

[24] Springer nature Link, Of, for, and by the people: the legal lacuna of synthetic persons | Artificial Intelligence and Law, (last visited June 19, 2025)

[25] Naruto v. Slater, 888 F.3d 418 (9th Cir. 2018).

[26] Copyright.gov U.S. Copyright Office, https://www.copyright.gov/ai/ (last visited June 19, 2025)

[27] Ministry of Law and Justice, https://pib.gov.in/PressReleasePage.aspx?PRID=2113224 (last visited June 19, 2025)

[28] Indian Contract Act, 1872, §11, No. 9, Acts of Parliament, 1872 (India)

[29] Animal Welfare Board of India v. A. Nagaraja, (2014) 7 SCC 547

[30] Supra Note 8