#FactCheck - AI Generated Photo Circulating Online Misleads About BARC Building Redesign

Executive Summary:

A misleading video claiming to show fireworks at Dubai International Cricket Stadium following India’s 2025 ICC Champions Trophy win has gone viral, causing confusion among viewers. Our investigation confirms that the video is unrelated to the cricket tournament. It actually depicts the fireworks display from the December 2024 Arabian Gulf Cup opening ceremony at Kuwait’s Jaber Al-Ahmad Stadium. This incident underscores the rapid spread of outdated or misattributed content, particularly in relation to significant sports events, and highlights the need for vigilance in verifying such claims.

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Claim: 

The circulated video claims fireworks and a drone display at Dubai International Cricket Stadium after India's win in the ICC Champions Trophy 2025.

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Fact Check:

A reverse image search of the most prominent keyframes in the viral video led it back to the opening ceremony of the 26th Arabian Gulf Cup, which was hosted by Jaber Al-Ahmad International Stadium in Kuwait on December 21, 2024. The fireworks seen in the video correspond to the imagery in this event. A second look at the architecture of the stadium also affirms that the venue is not Dubai International Cricket Stadium, as asserted. Additional confirmation from official sources and media outlets verifies that there was no such fireworks celebration in Dubai after India's ICC Champions Trophy 2025 win. The video has therefore been misattributed and shared with incorrect context.

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Fig: Claimed Stadium Picture

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Conclusion:

A viral video claiming to show fireworks at Dubai International Cricket Stadium after India's 2025 ICC Champions Trophy win is misleading. Our research confirms the video is from the December 2024 Arabian Gulf Cup opening ceremony at Kuwait’s Jaber Al-Ahmad Stadium. A reverse image search and architectural analysis of the stadium debunk the claim, with official sources verifying no such celebration took place in Dubai. The video has been misattributed and shared out of context.

• Claim: Fireworks in Dubai celebrate India’s Champions Trophy win.
• Claimed On: Social Media
• Fact Check: False and Misleading

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Modern international trade heavily relies on data transfers for the exchange of digital goods and services. User data travels across multiple jurisdictions and legal regimes, each with different rules for processing it. Since international treaties and standards for data protection are inadequate, states, in an effort to protect their citizens' data, have begun extending their domestic privacy laws beyond their borders. However, this opens a Pandora's box of legal and administrative complexities for both, the data protection authorities and data processors. The former must balance the harmonization of domestic data protection laws with their extraterritorial enforcement, without overreaching into the sovereignty of other states. The latter must comply with the data privacy laws in all states where it collects, stores, and processes data. While the international legal community continues to grapple with these challenges, India can draw valuable lessons to refine the Digital Personal Data Protection Act, 2023 (DPDP) in a way that effectively addresses these complexities.

Why Extraterritorial Application? 

Since data moves freely across borders and entities collecting such data from users in multiple states can misuse it or use it to gain an unfair competitive advantage in local markets, data privacy laws carry a clause on their extraterritorial application. Thus, this principle is utilized by states to frame laws that can ensure comprehensive data protection for their citizens, irrespective of the data’s location.  The foremost example of this is the European Union’s (EU) General Data Protection Regulation (GDPR), 2016,  which applies to any entity that processes the personal data of its citizens, regardless of its location. Recently, India has enacted the DPDP Act of 2023, which includes a clause on extraterritorial application.

The Extraterritorial Approach: GDPR and DPDP Act

The GDPR is considered the toughest data privacy law in the world and sets a global standard in data protection. According to Article 3, its provisions apply not only to data processors within the EU but also to those established outside its territory, if they offer goods and services to and conduct behavioural monitoring of data subjects within the EU. The enforcement of this regulation relies on heavy penalties for non-compliance in the form of fines up to €20 million or 4% of the company’s global turnover, whichever is higher, in case of severe violations. As a result, corporations based in the USA, like Meta and Clearview AI, have been fined over  €1.5 billion and €5.5 million respectively, under the GDPR. 

Like the GDPR, the DPDP Act extends its jurisdiction to foreign companies dealing with personal data of data principles within Indian territory under section 3(b). It has a similar extraterritorial reach and prescribes a penalty of up to Rs 250 crores in case of breaches. However, the Act or DPDP Rules, 2025, which are currently under deliberation, do not elaborate on an enforcement mechanism through which foreign companies can be held accountable. 

Lessons for India’s DPDP on Managing Extraterritorial Application 

1. Clarity in Definitions: GDPR clearly defines ‘personal data’, covering direct information such as name and identification number,  indirect identifiers like location data, and, online identifiers that can be used to identify the physical, physiological, genetic, mental, economic, cultural, or social identity of a natural person. It also prohibits revealing special categories of personal data like religious beliefs and biometric data to protect the fundamental rights and freedoms of the subjects. On the other hand, the DPDP Act/ Rules define ‘personal data’ vaguely, leaving a broad scope for Big Tech and ad-tech firms to bypass obligations. 
2. International Cooperation: Compliance is complex for companies due to varying data protection laws in different countries. The success of regulatory measures in such a scenario depends on international cooperation for governing cross-border data flows and enforcement. For DPDP to be effective, India will have to foster cooperation frameworks with other nations. 
3. Adequate Safeguards for Data Transfers: The GDPR regulates data transfers outside the EU via pre-approved legal mechanisms such as standard contractual clauses or binding corporate rules to ensure that the same level of protection applies to EU citizens’ data even when it is processed outside the EU. The DPDP should adopt similar safeguards to ensure that Indian citizens’ data is protected when processed abroad.
4. Revised Penalty Structure: The GDPR mandates a penalty structure that must be effective, proportionate, and dissuasive. The supervisory authority in each member state has the power to impose administrative fines as per these principles, up to an upper limit set by the GDPR. On the other hand, the DPDP’s penalty structure is simplistic and will disproportionately impact smaller businesses. It must take into regard factors such as nature, gravity, and duration of the infringement, its consequences, compliance measures taken, etc.
5. Governance Structure: The GDPR envisages a multi-tiered governance structure comprising of   

• National-level Data Protection Authorities (DPAs) for enforcing national data protection laws and the GDPR, 
• European Data Protection Supervisor (EDPS) for monitoring the processing of personal data by EU institutions and bodies,  
• European Commission (EC) for developing GDPR legislation
• European Data Protection Board (EDPB) for enabling coordination between the EC, EDPS, and DPAs

In contrast, the Data Protection Board (DPB) under DPDP will be a single, centralized body overseeing compliance and enforcement. Since its members are to be appointed by the Central Government, it raises questions about the Board’s autonomy and ability to apply regulations consistently. Further, its investigative and enforcement capabilities are not well defined.

Conclusion 

The protection of the human right to privacy ( under the International Covenant on Civil and Political Rights and the Universal Declaration of Human Rights) in today’s increasingly interconnected digital economy warrants international standard-setting on cross-border data protection. In the meantime, States relying on the extraterritorial application of domestic laws is unavoidable. While India’s DPDP takes measures towards this, they must be refined to ensure clarity regarding implementation mechanisms. They should push for alignment with data protection laws of other States, and account for the complexity of enforcement in cases involving extraterritorial jurisdiction. As India sets out to position itself as a global digital leader, a well-crafted extraterritorial framework under the DPDP Act will be essential to promote international trust in India’s data governance regime.

Sources

• https://gdpr-info.eu/art-83-gdpr/ 
• https://gdpr-info.eu/recitals/no-150/ 
• https://gdpr-info.eu/recitals/no-51/ 
• https://www.meity.gov.in/static/uploads/2024/06/2bf1f0e9f04e6fb4f8fef35e82c42aa5.pdf 
• https://www.eqs.com/compliance-blog/biggest-gdpr-fines/#:~:text=ease%20the%20burden.-,At%20a%20glance,In%20summary 
• https://gdpr-info.eu/art-3-gdpr/ 
• https://www.legal500.com/developments/thought-leadership/gdpr-v-indias-dpdpa-key-differences-and-compliance-implications/#:~:text=Both%20laws%20cover%20'personal%20data,of%20personal%20data%20as%20sensitive. 

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Introduction

The Telecom Regulatory Authority of India (TRAI) has directed all telcos to set up detection systems based on Artificial Intelligence and Machine Learning (AI/ML) technologies in order to identify and control spam calls and text messages from unregistered telemarketers (UTMs).

The TRAI Directed telcos

The telecom regulator, TRAI, has directed all Access Providers to detect Unsolicited commercial communication (UCC)by systems, which is based on Artificial Intelligence and Machine Learning to detect, identify, and act against senders of Commercial Communication who are not registered in accordance with the provisions of the Telecom Commercial Communication Customer Preference Regulations, 2018 (TCCCPR-2018). Unregistered Telemarketers (UTMs) are entities that do not register with Access Providers and use 10-digit mobile numbers to send commercial communications via SMS or calls.

TRAI steps to curb Unsolicited commercial communication

TRAI has taken several initiatives to reduce Unsolicited Commercial Communication (UCC), which is a major source of annoyance for the public. It has resulted in fewer complaints filed against Registered Telemarketers (RTMs). Despite the TSPs’ efforts, UCC from Unregistered Telemarketers (UTMs) continues. Sometimes, these UTMs use messages with bogus URLs and phone numbers to trick clients into revealing crucial information, leading to financial loss.

To detect, identify, and prosecute all Unregistered Telemarketers (UTMs), the TRAI has mandated that Access Service Providers implement the UCC.

Detect the System with the necessary functionalities within the TRAI’s Telecom Commercial Communication Customer Preference Regulations, 2018 framework.

Access service providers have implemented such detection systems based on their applicability and practicality. However, because UTMs are constantly creating new strategies for sending unwanted communications, the present UCC detection systems provided by Access Service providers cannot detect such UCC.

TRAI also Directs Telecom Providers to Set Up Digital Platform for Customer Consent to Curb Promotional Calls and Messages.

Unregistered Telemarketers (UTMs) sometimes use messages with fake URLs and phone numbers to trick customers into revealing essential information, resulting in financial loss.

TRAI has urged businesses like banks, insurance companies, financial institutions, and others to re-verify their SMS content templates with telcos within two weeks. It also directed telecom companies to stop misusing commercial messaging templates within the next 45 days.

The telecom regulator has also instructed operators to limit the number of variables in a content template to three. However, if any business intends to utilise more than three variables in a content template for communicating with their users, this should be permitted only after examining the example message, as well as adequate justifications and justification.

In order to ensure consistency in UCC Detect System implementations, TRAI has directed all Access Providers to deploy UCC and detect systems based on artificial intelligence and Machine Learning that are capable of constantly evolving to deal with new signatures, patterns, and techniques used by UTMs.

Access Providers have also been directed to use the DLT platform to share intelligence with others. Access Providers have also been asked to ensure that such UCC Detect System detects senders that send unsolicited commercial communications in bulk and do not comply with the requirements. All Access Providers are directed to follow the instructions and provide an update on actions done within thirty days.

The move by TRAI is to curb the menacing calls as due to this, the number of scam cases is increasing, and now a new trend of scams started as recently, a Twitter user reported receiving an automated call from +91 96681 9555 with the message “This call is from Delhi Police.” It then asked her to stay in the queue since some of her documents needed to be picked up. Then he said he works as a sub-inspector at the Kirti Nagar police station in New Delhi. He then inquired whether she had recently misplaced her Aadhaar card, PAN card, or ATM card, to which she replied ‘no’. The scammer then poses as a cop and requests that she authenticate the last four digits of her card because they have found a card with her name on it. And a lot of other people tweeted about it.

Conclusion

TRAI directed the telcos to check the calls and messages from Unregistered numbers. This step of TRAI will curb the pesky calls and messages and catch the Frauds who are not registered with the regulation. Sometimes the unregistered sender sends fraudulent links, and through these fraudulent calls and messages, the sender tries to take the personal information of the customers, which results in financial losses.