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Is Pakistan Ready for Deepfakes? Evaluating the Legal Response to AI-Generated Deception.

Authored By: Zainab Faheem Khan

Institute of Law - University of Sindh

Introduction. 

A video appears online showing a politician announcing an election boycott. Due to which his supporters panic and opponents celebrate. Journalists rush to verify it, but before any  clarification comes, the clip has already been shared thousands of times. Later, it turns out to be  false as the person in the video never said those words. The face was familiar. The voice sounded  real. The damage, however, was already done. 

This is the legal difficulty created by deepfakes. They do not merely spread false  information. They borrow the identity of a real person and place that identity inside a manufactured  reality. That is why deepfakes pose a special challenge for law. A legal system designed for  ordinary cybercrimes, defamation, obscenity and fraud may punish some consequences of  deepfake misuse, but it may still fail to understand the technology’s deeper harm. 

Pakistan is not without law. The Prevention of Electronic Crimes Act, 2016; the Pakistan  Penal Code; the Defamation Ordinance, 2002 and Qanun-e-Shahadat Order, 1984 may all be  relevant in different situations. In addition, the PECA Amendment Act 2025 added section 26A  on false and fake information and created the National Cyber Crime Investigation Agency. Yet, the central question remains that, has Pakistan built a legal response that is specific, victim-centred,  technically capable and constitutionally balanced? Unfortunately, the answer, at present, is no.  Pakistan has legal fragments, but not a coherent deepfake framework. 

What is deepfakes? And why its alarming? 

A deepfake is generally understood as an AI-generated or AI-manipulated video, image or  audio recording that makes a person appear to say or do something that did not happen. The  technology can replace faces, manipulate expressions, create synthetic faces and clone speech.1 Digital manipulation is not new, but artificial intelligence changes its scale and accessibility. What  previously required technical skill, editing experience and expensive tools can now be done more  easily, quickly and cheaply.2 These matters because law often reacts after harm has occurred, while  deepfakes travel at the great speed. 

The danger is made worse by the limits of detection. It is tempting to believe that  technology will solve the problem, if AI can generate deepfakes, perhaps AI can also detect them.  Detection tools are useful, but they cannot be treated as a complete legal answer. Deepfake  detection will not always be perfect, and creation techniques may advance faster than detection  systems.3 More importantly, detection only helps when it is actually used before the content  spreads. Nowadays, content circulates rapidly through WhatsApp, TikTok, Facebook, X and  informal political networks, a deepfake may reach its audience long before any journalist, platform  or investigator can test it. 

Types of deepfakes and it’s foreseeable effects in Pakistan. 

  1. Pornography: damaging reputation, dignity, identify, mental health and privacy. 

The first major public association of deepfakes was AI made celebrity pornography.4It  shows that deepfakes were never only about misinformation. They were also about control over  bodies, consent, dignity and sexual reputation. Studies have repeatedly shown that a very large  proportion of deepfake content online is pornographic in nature.5 Cases involving extortion,  revenge pornography and minors have also been reported internationally.6In this form of abuse,  victim’s body is fabricated, but to close to reality that it lead to the real humiliation. 

This is where Pakistani law faces one of its hardest tests. In Pakistan, reputation is not a  purely individual matter. Honour, family standing, religion, gender roles and community  perception can shape the victim’s entire social life. A deepfake targeting a woman may affect her  education, employment, marriage prospects and safety. Especially in societies like Pakistan, where  the victim may be blamed for being online in the first place. The women facing deepfake  harassment are often questioned rather than protected, and many respond by deleting their social  media profiles.7 

The legal point is simple a sexual deepfake is not merely “fake content”. It is a non consensual appropriation of identity. It violates privacy because intimate representation has been  created without permission. It violates dignity because the person is reduced to an object of sexual  display. It damages reputation because viewers may believe, or pretend to believe, that the material  is real. It may also cause mental harm, including fear, shame, social and mental isolation, anxiety  and loss of self-worth.8 A law that treats this only as obscenity or defamation misses the full  character of the wrong. Hence, the existing framework can never provide sufficient justice. 

  1. Political deepfakes: damaging democracy, public trust, and even manipulates election results. 

Deepfakes is also a threat to democracy. One example is, the 2024 general elections in  Pakistan showed this clearly. Fake AI-generated videos circulated online, including clips falsely  showing Imran Khan, Basharat Raja and Rehana Dar announcing election boycotts. Candidates  had to issue denials, and the public had to process political uncertainty in real time.9 The point is  not only that some voters may believe a fake video. The deeper danger is that voters may lose  

Victims in the European Union: Findings from a Comparative Legal Study’ (2024) 25(1) Trauma, Violence, & Abuse 117 https://doi.org/10.1177/15248380221143772 accessed 21 June 2026. confidence in all political information. Also, genuine evidence can be rejected by calling it AI generated. 

This is particularly dangerous in Pakistan’s already polarized political environment. Deepfakes may strengthen confirmation bias. People are more likely to accept manipulated content  when it fits what they already believe, about political rivals.10 Emotion often travels way faster  than verification,11 which requires patience and evaluation of one’s own self-believes. 

The risks become sharper when deepfakes are combined with microtargeting. Data-driven  systems can tailor content to individuals based on demographics, behavior, personality and online  habits.12 Deepfakes can then be adapted to what a particular audience is most likely to believe or  fear.13 Material shows that political deepfakes can affect attitudes, especially when combined with  microtargeting.14 This creates a serious democratic problem: manipulation becomes personalized,  emotionally precise and difficult to observe at scale. 

Pakistan existing framework for addressing deepfakes and its short  comings. 

Pakistan’s legal framework is poorly prepared for that kind of harm. PECA 2016 was  drafted in an earlier digital era. It covers unauthorized access, data misuse, cyber fraud, identity related offences, online harassment and certain forms of harmful content.15 Some provisions can  be applied to deepfakes. For example, section 21 may be relevant to non-consensual intimate  images; section 20 may be used in online defamation; other provisions may deal with fraud, identity theft or cyberstalking. The PPC may also help in cases involving false evidence, electoral  false statements, impersonation, obscenity, religious hatred or public unrest.16 Defamation law  may provide a civil route where reputation is harmed.17 

It punishes selected outcomes, not the deepfake wrong itself. If a deepfake is sexually  explicit, one provision may apply. If it causes reputational harm, defamation may be considered.  If it is used to cheat someone, fraud provisions may be invoked. If it creates public disorder, section  26A may be relevant. But many harmful deepfakes do not fit neatly into these categories. 

Absence of clear statutory definitions: 

The absence of clear statutory definitions is one of the largest gaps. PECA does not  adequately define “deepfake”, “synthetic media”, “AI-generated likeness”, “voice cloning” or  “non-consensual digital impersonation”.18 Without such definitions, it creates inconsistency. One  officer may treat a complaint as defamation. Another may treat it as obscenity. A third may say no  offence is clearly made out. Victims are then left navigating uncertainty at the very moment when  time matters most. 

Reactive design: 

Another weakness is the law’s reactive design. Deepfakes spread first; the law responds  later. PECA’s content removal structure depends heavily on complaints and post-publication  action.19 The 2025 amendment does introduce a 24-hour mechanism for removal or blocking of  fake and false information. That sounds useful on paper. But even twenty-four hours can be a  lifetime online. The legal response must therefore, include urgent preservation of evidence, rapid  takedown, victim protection and platform cooperation. Removal alone is not enough and never  sufficient. 

Lack of Platform responsibility: 

Platform responsibility is another unresolved issue. Section 38 of PECA protects service  providers from automatic liability unless actual knowledge and intention to assist unlawful activity  are proven.20 This protection was originally meant to encourage digital services and avoid unfairly  punishing intermediaries for every user’s conduct. That policy has value and platforms should not  be made criminally liable for everything users upload. But deepfakes expose the weakness of a  purely passive model. If platforms repeatedly host, recommend and amplify synthetic abuse,  should they have no duty beyond responding to complaints? The answer should not be unlimited  liability, but proportionate responsibility. 

Suggestions: 

Pakistan needs a balanced model. Platforms should be required to maintain accessible  reporting channels, preserve evidence after complaints, act quickly in cases involving sexual  deepfakes, election manipulation or threats to life, and cooperate with lawful investigation. They  should also publish transparency reports on synthetic media complaints and takedown times.  However, general mandatory monitoring of all content would be dangerous. It could lead to  censorship, over-removal and surveillance. The goal should be targeted due diligence, not  uncontrolled state control over speech. Otherwise, it will lead to more problems rather than a  solution. 

This distinction matters because Pakistan’s cybercrime laws have often been criticized for  vagueness and misuse. Broad provisions dealing with false information, insult, public order or  morality may be used not only against genuine harm but also against journalists, political critics  and ordinary users.21 The PECA Amendment Act 2025 adds section 26A, criminalizing an  intentional dissemination of false or fake information that is likely to cause fear, panic, disorder or  unrest. The provision may help address some harmful disinformation. However, it also raises a  serious constitutional concern. 

This is the central reform dilemma. Pakistan needs stronger law against deepfakes, but not  a vague law that becomes a tool of censorship. Any deepfake legislation should target clearly  defined harmful conduct, including creation and distribution of non-consensual sexual deepfakes,  fraud, impersonation, fabricated evidence, election-related deception, and content that incites  violence or hatred. Liability should depend on proven intent, knowledge, or recklessness.  However, safeguards must protect legitimate uses such as satire, journalism, artistic expression,  and academic research where there is no intent to deceive Evidence is another area where deepfakes create legal difficulty. Courts traditionally assess  electronic evidence by examining authenticity, reliability, integrity and chain of custody under the  Qanun-e-Shahadat framework.22 A video may look like direct evidence while being entirely  fabricated. Conversely, a real video may be dismissed as fake. This creates risk of both wrongful  conviction and wrongful acquittal. Courts therefore need stronger procedures for digital  authentication. A deepfake framework should require forensic examination where authenticity is  disputed, preservation of metadata where available, chain-of-custody standards, expert evidence  protocols and caution before relying on viral media. 

The law should also recognize that deepfake harm is not only criminal. Victims need civil  and protective remedies. Pakistan should create a fast civil protection route allowing courts or a  specialized tribunal to order urgent takedown, preservation of evidence, non-publication, de indexing, disclosure of uploader information subject to due process, and compensation. In sexual  deepfake cases, victim anonymity should be protected. Proceedings should avoid forcing victims  to repeatedly display or describe the material unless strictly necessary. The system must not  become a second punishment. 

Institutional capacity is equally important. There is a clear lack of technical expertise  within enforcement agencies and the need for cyber forensic units, specialized training and better  resources.23 The establishment of the NCCIA is a positive step, but institutional reform alone  cannot address the deepfake threat. Effective enforcement requires specialized training for investigators, prosecutors, and judges in AI-generated evidence, digital forensics, and victim centered approaches. 

Jurisdiction remains a further challenge. Deepfakes can be created abroad, uploaded  through foreign platforms, shared through encrypted channels and monetized anonymously.  Pakistan’s domestic law has limited practical reach when perpetrators, servers or platforms are  outside the country.24 Pakistan needs stronger international cooperation arrangements, channels  and emergency preservation request procedures. 

Data protection must be part of law. Deepfakes are built from data like photographs, videos,  voice samples and personal information. Pakistan’s weak personal data protection environment  increases vulnerability. Vulnerabilities as to data breaches, sale of personal data and poor privacy  ranking concerns.25 A serious deepfake policy must therefore include a strong data protection law,  duties on entities handling biometric and facial data, restrictions on scraping personal images, and  penalties for unauthorized collection or sale of personal information. 

A rights-based framework should begin with the Constitution. Article 14 of the  Constitution of Pakistan protects dignity and privacy. Deepfakes attack both. They also affect  freedom of expression, political participation, access to information and fair trial rights. The state  must therefore avoid two mistakes. The first mistake is under-regulation, leaving victims to rely  on scattered provisions while harm multiplies. The second mistake is over-regulation: using the  language of fake news to suppress dissent. A democratic legal framework must protect citizens  from synthetic abuse without giving the state unchecked authority to decide truth in political  debate. 

The most workable reform would be a separate Synthetic Media and Digital Likeness Act.  It should define deepfakes and synthetic media clearly. It should recognize digital likeness, voice  and intimate identity as protectable interests. It should create aggravated offences for sexual  deepfakes, election manipulation, extortion, fraud, child-related content, religious or sectarian incitement and fabricated evidence. It should provide urgent takedown and evidence preservation.  It should impose proportionate platform obligations. It should require labelling of materially  deceptive synthetic media in political advertising. It should create forensic standards for courts.  And it should include safeguards for journalism, parody, research and whistleblowing. 

Public education is also essential. No law can examine every video before it is seen.  Citizens need digital literacy as how to pause before sharing, how to check sources, how to report  abuse, and how to understand that realism is no longer proof. Election bodies, media regulators,  schools, universities, political parties and civil society should run awareness campaigns before  elections, not after harm. 

Conclusion: 

Pakistan is not ready for deepfakes if readiness means having a complete legal, institutional  and social response. But Pakistan is also not helpless. The existing legal framework contains useful  starting points. PECA can address some cyber harms. The PPC can punish fraud, false evidence  and public-order offences. Defamation law may protect reputation. The Constitution protects  dignity and privacy. The 2025 amendment shows that the state is aware of false information as a  legal issue. 

Deepfakes are not ordinary lies but, identity-based fabrications. They damage reputation,  privacy, dignity, democracy and evidence at the same time. A person whose face is stolen for  sexual abuse, a voter deceived by a fake political video, and a court misled by synthetic evidence  are not facing three separate problems. They are facing one modern problem: the collapse of trust  in digital reality. 

Pakistan’s response must therefore be specific, fast, technically informed and rights respecting. It must protect victims without criminalizing dissent. It must demand responsibility  from platforms without turning them into private censors. It must train investigators and judges  instead of merely creating new agencies. Also, it must treat consent, dignity and authenticity as  central legal values.

Bibliography. 

Table of Legislation 

Defamation Ordinance 2002. 

Pakistan Penal Code 1860. 

Prevention of Electronic Crimes Act 2016. 

Bibliography 

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Ameer S, ‘Deepfakes: A Crisis of Human Rights’ (Research Society of International Law,  19 April 2024) https://rsilpak.org/2024/deepfakes-a-crisis-of-human-rights/ accessed 21 June  2026. 

Blesik T, Murawski M, Vurucu M and Bick M, ‘Applying Big Data Analytics to  Psychometric Micro-Targeting’ in Machine Learning for Big Data Analysis (2018). 

Daqiq B, ‘Investigating Experiences of Afghan Female University Students towards  Online Harassment’ (2023) Cogent Social Sciences https://doi.org/10.1080/23311886.2023.2192440 accessed 21 June 2026. 

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Dobber T, Metoui N, Trilling D, Helberger N and De Vreese C, ‘Do Microtargeted  Deepfakes Have Real Effects on Political Attitudes?’ (2021) 26(1) The International Journal of  Press/Politics 69. 

FBI San Francisco, ‘FBI Warns of Increasing Threat of Cyber Criminals Utilizing Artificial  Intelligence’ (FBI, 2024) https://www.fbi.gov/contact-us/field-offices/sanfrancisco/news/fbi-

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Hameleers M, ‘Separating Truth from Lies: Comparing the Effects of News Media Literacy  Interventions and Fact-Checkers in Response to Political Misinformation in the US and  Netherlands’ (2022) 25(1) Information, Communication & Society 110. 

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Kazmi SMA, ‘“It Is All Her Fault”: Psychosocial Correlates of the Negative Attitudes  towards Rape Victims among the General Population of Pakistan’ (2023) Egyptian Journal of  Forensic Sciences https://doi.org/10.1186/s41935-022-00320-3 accessed 21 June 2026. 

Kosinski M, ‘Using Big Data’ in Handbook of Social Psychology (2024). 

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Shah S, ‘Navigating the Deepfake Dilemma in Pakistan’ (SSRN, 5 May 2025)  https://ssrn.com/abstract=6618978 accessed 21 June 2026. 

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1 Timothy M. Persons, PhD, Chief Scientist, United States Government Accountability Office, Science & Tech  Spotlight: Deepfakes (GAO-20-379SP, 20 February 2020) https://www.gao.gov/products/gao-20-379sp accessed 21  June 2026.

2 A O J Kwok and S G M Koh, ‘Deepfake: A Social Construction of Technology Perspective’ (2021) 24(13) Current  Issues in Tourism 1798 https://doi.org/10.1080/13683500.2020.1738357 accessed 21 June 2026.

3 Villasenor J, ‘Artificial Intelligence, Deepfakes, and the Uncertain Future of Truth’ (Brookings Institution, 14  February 2019) https://www.brookings.edu/articles/artificial-intelligence-deepfakes-and-the-uncertain-future-of truth/ accessed 21 June 2026. 

4 Dean Fido, Jaya Rao and Craig A Harper, ‘Celebrity Status, Sex, and Variation in Psychopathy Predicts Judgements  of and Proclivity to Generate and Distribute Deepfake Pornography’ (2022) 129 Computers in Human Behavior 107141 https://doi.org/10.1016/j.chb.2021.107141 accessed 21 June 2026.; M Popova, ‘Deepfakes: An Introduction’  (2020) 7(4) Porn Studies 350 https://doi.org/10.1080/23268743.2020.1837659 accessed 21 June 2026.; Mika  Westerlund, ‘The Emergence of Deepfake Technology: A Review’ (2019) Technology Innovation Management  Review https://doi.org/10.22215/timreview/1282 accessed 21 June 2026. 

5 Henry Ajder, Giorgio Patrini, Francesco Cavalli and Laurence Cullen, The State of Deepfakes: Landscape, Threats,  and Impact (Deeptrace 2019) 27. 

6 FBI San Francisco, ‘FBI Warns of Increasing Threat of Cyber Criminals Utilizing Artificial Intelligence’ (FBI, 2024)  https://www.fbi.gov/contact-us/field-offices/sanfrancisco/news/fbi-warns-of-increasing-threat-of-cyber-criminals utilizing-artificial-intelligence accessed 21 June 2026.; K Mania, ‘Legal Protection of Revenge and Deepfake Porn 

7 Syed Messum Ali Kazmi, ‘“It Is All Her Fault”: Psychosocial Correlates of the Negative Attitudes towards Rape  Victims among the General Population of Pakistan’ (2023) Egyptian Journal of Forensic Sciences  https://doi.org/10.1186/s41935-022-00320-3 accessed 21 June 2026.; Besmillah Daqiq, ‘Investigating Experiences of  Afghan Female University Students towards Online Harassment’ (2023) Cogent Social Sciences  https://doi.org/10.1080/23311886.2023.2192440 accessed 21 June 2026. 

8 Sarah Ameer, ‘Deepfakes: A Crisis of Human Rights’ (Research Society of International Law, 19 April 2024)  https://rsilpak.org/2024/deepfakes-a-crisis-of-human-rights/ accessed 21 June 2026.; Anastasia Powell, Asher Flynn,  Adrian J Scott and Emma Cama, ‘Deepfakes and Digitally Altered Imagery Abuse: A Cross-Country Exploration of  an Emerging Form of Image-Based Sexual Abuse’ (2022) 62(6) British Journal of Criminology 1341.; Victoria  Rousay, ‘Sexual Deepfakes and Image-Based Sexual Abuse: Victim-Survivor Experiences and Embodied Harms’  (Master’s thesis, Harvard University 2023). 

9 Nilofar Mughal, ‘Deepfakes, Internet Access Cuts Make Election Coverage Hard, Journalists Say’ VOA News (22  February 2024) accessed 21 June 2026.

10 O Debroy, ‘Psycho-Social Impact of Deepfake Content in Entertainment Media’ (2024) 10(5) International Journal  for Innovative Research in Multidisciplinary Field 235 http://dx.doi.org/10.2015/IJIRMF/202405032 accessed 21  June 2026. 

11 M Jimoh, ‘The Right to Democratic Participation in Africa in the Era of Deepfake’ (2023) 17 Pretoria Student Law  Review 106 https://ssrn.com/abstract=4834393 accessed 21 June 2026. 

12 T Blesik, M Murawski, M Vurucu and M Bick, ‘Applying Big Data Analytics to Psychometric Micro-Targeting’ in  Machine Learning for Big Data Analysis (2018) 1.; Michal Kosinski, ‘Using Big Data’ in Handbook of Social  Psychology (2024). 

13 Michal Kosinski, ‘Using Big Data’ in Handbook of Social Psychology (2024).; Tom Dobber, Nadia Metoui, Damian  Trilling, Natali Helberger and Claes de Vreese, ‘Do Microtargeted Deepfakes Have Real Effects on Political  Attitudes?’ (2021) 26(1) The International Journal of Press/Politics 69.; Ronan Ó Fathaigh, Tom Dobber, Frederik  Zuiderveen Borgesius and James Shires, ‘Microtargeted Propaganda by Foreign Actors: An Interdisciplinary  Exploration’ (2021) 28(6) Maastricht Journal of European and Comparative Law 856. 

14 Tom Dobber, Nadia Metoui, Damian Trilling, Natali Helberger and Claes de Vreese, ‘Do Microtargeted Deepfakes  Have Real Effects on Political Attitudes?’ (2021) 26(1) The International Journal of Press/Politics 69.

15 Prevention of Electronic Crimes Act 2016.

16 Pakistan Penal Code 1860. 

17 Defamation Ordinance 2002. 

18 Rao Saad Mansoor, ‘AI and Data Protection in Pakistan: Outdated State Laws and Vulnerability of Personal Data’  (The Institute of Legal Studies, 2025) https://tils.edu.pk/wp-content/uploads/2025/05/AI-and-Data-Protection-In Pakistan-Outdated-State-Laws-and-Vulnerability-of-Personal-Data.htm accessed 21 June 2026.

19 Saliha Shah, ‘Navigating the Deepfake Dilemma in Pakistan’ (SSRN, 21 June 2026)  https://ssrn.com/abstract=6618978 accessed 21 June 2026.

20 Ibid. 

21 Pakistan’s Cybercrime Law Being Used as “Tool” against Freedom of Expression, Journalists — Watchdog’ Arab  News (accessed 21 June 2026) https://www.arabnews.com/node/2596269/amp

22 Maximilian Hameleers, ‘Separating Truth from Lies: Comparing the Effects of News Media Literacy Interventions  and Fact-Checkers in Response to Political Misinformation in the US and Netherlands’ (2022) 25(1) Information,  Communication & Society 110. 

23 Rao Saad Mansoor, ‘AI and Data Protection in Pakistan: Outdated State Laws and Vulnerability of Personal Data’  (The Institute of Legal Studies, 2025) https://tils.edu.pk/wp-content/uploads/2025/05/AI-and-Data-Protection-In Pakistan-Outdated-State-Laws-and-Vulnerability-of-Personal-Data.htm accessed 21 June 2026.

24 Pakistan’s Cybercrime Law Being Used as “Tool” against Freedom of Expression, Journalists — Watchdog’ Arab  News (accessed 21 June 2026) https://www.arabnews.com/node/2596269/amp 

25 Hija Turabi, ‘Protecting Personal Info’ Dawn (17 April 2023) https://www.dawn.com/news/1747903 accessed 21  June 2026.; S Abbasi, ‘Pakistan’s Web of Cyber Scammers’ Dawn (16 July 2023)  https://www.dawn.com/news/1764628 accessed 21 June 2026.

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