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WHEN STYLE BECOMES SELF: GHIBLI AND PERSONALITY RIGHTS

-       Vageesha Chandrakar[1] & Yashsasvee Jain[2]

 

 

I.       ABSTRACT

AI-generated images in the style of Ghibli constitute a violation of the personality rights of Hayao Miyazaki. The Ghibli style is associated with Studio Ghibli and its co-founder Miyazaki. However, they do not possess copyright over it, as it represents a manner of creating artwork. Recently, AI platforms have enabled users to generate images in this style, raising significant concerns about unauthorized association and exploitation. This paper examines the jurisprudence of personality rights in India and argues that Miyazaki’s personality rights over Ghibli style should be recognized to prevent such misuse. The recognition of these rights would protect Miyazaki’s persona and creative identity from unscrupulous exploitation by AI platforms.

Keywords: Copyright; AI; Art style; Human Rights; Moral Rights; Personality rights; Ownership.

 

II.     INTRODUCTION

‘Ghibli Art trend’ sparked a legal discourse on copyright protection over artistic styles. It was asserted that Ghibli style, being an idea or a concept, was not entitled to such protection. This led to endless AI images being created mimicking art style of Studio Ghibli. The trend brought unwarranted association of the Studio Ghibli and its co-founder Hayao Miyazaki to the AI generated images.

Studio Ghibli & Miyazaki are globally known for their animated films and as such their identity is closely tied with the specific art style that has been replicated by the AI models. The personality rights can be extended over the Ghibli style to restrain its association with AI-generated Ghibli images. Thus, the article argues that protection over Ghibli style must be extended to preserve their rights and to restrain users from generating such images. 

 

III.   ARTISTIC STYLE: A PORTRAIT OF SELF 

Artistic style refers to the form and manner of depicting artwork. It consists of features that remain consistent throughout the work and is often identified with a particular period or person. An art style associated with an individual represents their self, persona, and artistic ideals. It enables portraying one’s beliefs, experiences, and emotions.

The artistic style of an author gives their ideas a visual persona. This style forms part of the process that gives viewers an insight into the artists’ perception. This can be understood by examples like Caravaggio being known to develop chiaroscuro, Andy Warhol's Pop Imagery, Kahlo's surrealist portraits, Banksy’s provocative and political street art and many more examples where a certain art style finds its name attached to an artist.[3] Another notable example is the Ghibli style, associated with Studio Ghibli and its co-founder Hayao Miyazaki.[4] It is characterized by soft pastel colour palettes, intricate backdrops, and expressive, vivid characters. These attributes have long been associated with this animation studio.

Since the development of any art style necessitates inspiration from all those who have come before it as well as from those who draw inspiration from it in the future, it is only reasonable that these artists do not possess any exclusive rights over any particular style. At present, Copyright laws do not protect art styles as these are seen to exist as a method of expression rather than an individualistic expression itself. Extending copyright over particular styles would hinder other artists from drawing inspiration from these art styles and prevent their ability to develop and express themselves. In R.G. Anand v. Delux Films[5], the Supreme Court held that ideas or themes are not copyrightable. Similarly, the US copyright circular 33 mentions that there can be no protection of copyright over “any idea, procedure, process, system, method of operation, concept, principle, or discovery, regardless of the form in which it is described, explained, illustrated, or embodied.”[6] Due to these, an art style is interpreted as being an idea or a concept which anyone can use. 

However, a shift in perspective is required in the present times. In March, OpenAI launched a new image generator that enabled the public to transform any image in the style of Ghibli.[7] It took the internet by storm, with millions of people using ChatGPT to mimic the style and produce “Ghiblified” versions of images. Currently, numerous AI generators allow instant conversion of images into the Ghibli style. As a result, a process which earlier took countless hours can now be replicated in mere moments by AI to produce a similar output. 

It is argued that AI-generated images resemble replication of Studio Ghibli more than mere inspiration. While human artists incorporate influences, their unique styles emerge, providing authenticity through creativity and effort. In contrast, AI lacks an individual artist, leading to a production that substantially replicates original art without creative input or labour, undermining the authenticity found in human-made works.

 

IV.   THE PERSONA SHIELD: DEFINING AND DEFENDING IDENTITY

Celebrities inherently possess special rights over their personality known as personality rights.[8] These rights protect their persona or distinctive characteristics such as name, image, likeness, signature, gestures, vocal style, and other unique attributes. It allows famous individuals to control the commercial use of their identity and to safeguard their right to privacy.

Personality rights are considered an extension of moral rights. Moral rights protect the integrity and authorship of creative works, while personality rights allow individuals to prevent unauthorized commercial exploitation of their identity. Additionally, it can be viewed as a quasi-property right which, as Hegel argues, is justified because it supports, and perhaps necessitates, the development of personality: ownership serves as a safeguard for one’s “personhood.”[9] For instance, for artists, creative works are infused with their will and individuality, making the work an extension of their personality that is inseparable from their name.

In Indian law, while “celebrity” is not expressly defined in the Copyright Act, it can fall within the meaning of “performer.” Section 38B of the Act[10] grants performers moral rights, including the right to restrain any distortion, mutilation, or modification of their performance that could malign their reputation. Therefore, celebrities can also prevent misuse of their personality that damages their reputation. 

For example, in Shivaji Rao Gaikwad v. Varsha Productions,[11] the court granted injunction in favour of the actor Rajnikanth. It was alleged that his name, image, and style of delivering dialogues were used in the film “Main Hoon Rajnikanth”. The court noted that people associated the title of the film with the actor Rajnikanth who had not consented to such use of his name. This is why he was entitled to restrain the producers of the film from making any unauthorized use of his name. 

Presently, courts have extended this protection to modern scenarios involving AI. For example, in Anil Kapoor v. Simply Life India,[12] the court protected the plaintiff’s personality rights against misappropriation by AI platforms that generated derogatory deep fakes. Similarly, in Arijit Singh v. Codible Ventures LLP,[13] singer Arijit Singh filed a suit against platforms that imitated his voice and manner of singing, enabling users to insert his voice into songs without consent. The court held that attributes such as name, voice, likeness, and other personal characteristics are protectable facets of personality, and their unauthorized use infringes these rights.

The above cases highlight how technological advancements have opened up new avenues for people to produce or imitate celebrities’ names or likeness which jeopardise their personality rights. AI platforms, in particular, have made it easier to misuse these rights. In such circumstances, judicial protection becomes necessary to prevent their misappropriation for nefarious and unscrupulous purposes. 

 

V.     MIYAZAKI’S MARK: STYLE AS AN EXTENSION OF CREATIVE IDENTITY

Personality rights are infringed when firstly, the individual enjoys the status of a celebrity in society and is identifiable from the unauthorized work, and secondly, the use is substantial enough to exploit their persona or essential attributes.[14] 

It is asserted that the recent trend of generating images in the “Ghibli Art” style constitutes an infringement of Hayao Miyazaki’s personality rights. The AI generation of images tagged with the name of Studio Ghibli directly associates them with Hayao Miyazaki, the studio’s co-founder and an internationally celebrated filmmaker.

Miyazaki is an acclaimed artist and filmmaker whose identity is inseparably linked to Studio Ghibli’s distinctive artistic style, which has earned global accolades. The unique art style, developed and refined over decades, is not merely a commercial product but an extension of his personality and creative identity. It can be substantiated by the fact that the trend was even dubbed the “Ghibli Trend,” underscoring how the studio’s artistic expression has become synonymous with its creators’ names and reputations.

However, the generative AI tools that reproduce this style without authorization are exploiting his reputation and encroaching upon his personality rights. There are no restrictions placed on AI regarding what kind of images it can present in the Ghibli style. Without restraint, people have generated images depicting Miyazaki himself shaking hands with a robot, sexualized and racist Nazi illustrations and images of far more sensitive issues like political assassinations and even going so far as to 9/11 attacks, which goes against the ethos of Studio Ghibli and Miyazaki.[15] Moreover, an online video resurfaced at the time in which Miyazaki severely criticized an AI-generated animation project by calling it “an insult to life itself.”[16] He categorically refused to incorporate such a technology into his work. 

The online trend has caused unequivocal harm to the reputation and integrity of Studio Ghibli, on a simple google search of “Ghibli Art,” endless results show up, not of any original art by artists of the animation studio but of AI generated slop. Association of Studio Ghibli and Miyazaki with such AI generated images warrants recognition of Miyazaki’s personality rights over the Ghibli style and such platforms must be restrained from producing Ghibli style changes. 

 

VI.   THE MONETIZED MIMICRY: INNOVATION AT GHIBLI’S EXPENSE

The right of commercial exploitation of a work rests with its original creator.[17] It is the author who has the right to generate economic benefits from their creations. Celebrities spend their time, labour, and effort in establishing their brand value through their works. Subsequently, their distinctive attributes are etched in the minds of the public and are associated only with them. This is why they have the right to gain commercial benefits from these attributes. 

However, this right is usurped when their attributes are misused by another person without authorization. The profits that are owed to the celebrities are pocketed away by other individuals. Additionally, in the current online landscape, AI tools also facilitate violation of personality rights. For example, people are able to generate images using AI that is built on the unauthorized use of human artists’ work. The generated result may then be monetized by the end user as their own, with no real credit, permission, or compensation to the human artist to whom the source material belonged. 

The issue becomes further complicated when generative AI mimics the art style of an animation studio. The Ghibli trend illustrates this problem. Since no protection of copyright is extended to Studio Ghibli over their style of art, endless images have been created as part of an online trend.  By using the words “In the style of” along with “Ghibli” in the prompt, the AI model scrapes the internet for all the data tagged with this name. Thereafter, the model generates an “artwork” that follows the patterns and style of Studio Ghibli. This causes a substitutive effect in the market because the resulting image, being a closer replication of the source material, harms the business of the original artist. 

The unchecked commercial use of distinctive attributes and art styles through AI tools usurps the creator's fundamental right to commercial exploitation and compensation. Without a re-evaluation of existing legal frameworks, this digital landscape will continue to harm the integrity and business of original artists, allowing corporations and end-users to profit from unauthorized replication. The original artists must have some protection extended to them over their art styles being fed to monetized AI tools. 

 

VII. CONCLUSION

The ‘Ghibli trend’ illustrates how unauthorised imitation of art styles raises complex legal issues. While copyright does not extend to art styles, their replication by AI poses a problem- that an artist’s personality can be commercially exploited without their consent. Advancements in AI technology have enabled production of images by replicating artistic styles. Such innovation, however, has come at the expense of the artists as replication is done without authorisation or consent from those who have developed these styles and are identified with them. Artists and anyone working in the creative industry are constantly at risk from the process of AI training on art.

Studio Ghibli and Hayao Miyazaki have found themselves in this situation since OpenAI released a new image generator. Today, several AI platforms allow users to generate images in Ghibli style. In doing so, one important aspect is missed by the developers that is violation of personality rights of Miyazaki. Ghibli style is largely associated with Miyazaki’s work. In fact, one of the reasons why it became popular was that generated images were invoking the same warm and nostalgic feeling associated with Miyazaki’s work. However, the grim reality is that the ethos of Studio Ghibli and Miyazaki were not taken into consideration. The absence of limitations also led to the creation of images that are contrary to their values.

Under these circumstances, courts must provide recourse to artists by recognising that art styles can be an extension of an artist’s personality. Such recognition would allow artists to restrict AI platforms from generating images in their art styles without prior authorisation, thus preserving their personal identity. 


[1] Vageesha Chandrakar is a student at Hidayatullah National Law University.

[2] Yashsasvee Jain is a student at Hidayatullah National Law University.

[4] Kyle Chayka, The limits of AI-Generated Miyazaki, The New Yorker (Oct. 28, 2025, 4:00 PM), https://www.newyorker.com/culture/infinite-scroll/the-limits-of-ai-generated-miyazaki.

[5] (1978) 4 SCC 118.

[6] Copyright Office, Works Not Protected By Copyright 1 (2017), https://www.copyright.gov/circs/circ33.pdf.

[7] Hailey Quach, My Experience with Studio Ghibli Style AI Art: Ethical Debates in the GPT-4o Era, MEDIUM (Oct 28, 2025, 4:20 PM), https://medium.com/@haileyq/my-experience-with-studio-ghibli-style-ai-art-ethical-debates-in-the-gpt-4o-era-b84e5a24cb60.

[8] R. Rajagopal v. State of T.N., (1994) 6 SCC 632.

[9] Kanu Priya, Intellectual Property And Hegelian Justification, 1 NUJS L. Rev. 359, 8 (2016), https://nujslawreview.org/wp-content/uploads/2016/12/kanu_priya.pdf.

[10] The Copyright Act, 1957, § 38B, No. 14, Acts of Parliament, 1957 (India).

[11] 2015 SCC OnLine Mad 158.

[12] 2023 SCC OnLine Del 6914.

[13] 2024 SCC OnLine Bom 2445.

[14] D.M. Entertainment (P) Ltd. v. Baby Gift House, 2010 SCC OnLine Del 4790.

[15] Billy Perrigo, Ghibli Memes Flourish as OpenAI Embraces Trump-Era “Freedom,” TIME (Mar. 28, 2025), https://time.com/7272593/studio-ghibli-memes-trump-white-house/. THE STANDARD, https://www.standard.co.uk/news/tech/openai-limits-ai-images-studio-ghibli-chatgpt-b1219491.html (last visited Oct. 28, 2025), Miles Klee, Miyazaki Fans Sure Are Pissed About ChatGPT’s Studio Ghibli AI Slop, ROLLING STONE, (Oct. 28, 2025, 4:30 PM).

[17] Arijit Singh v. Codible Ventures LLP, 2024 SCC OnLine Bom 2445.

 
 
 

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