Delhi High Court’s Significant Ruling on AI Training and Copyright
On July 24, 2026, the Delhi High Court, presided over by Justice Amit Bansal, issued a pivotal judgment that could lay the groundwork for how Indian courts handle copyright disputes related to the training of large language models (LLMs). In the case of ANI Media Pvt. Ltd. v. Open AI Opco LLC [CS(COMM) 1028/2024], the court denied ANI Media’s request for an interim injunction against OpenAI. The court ruled that OpenAI’s use of ANI’s literary works for training the LLMs underlying ChatGPT falls under “private or personal use, including research,” as per Section 52(1)(a) of the Copyright Act, 1957. Furthermore, ChatGPT’s outputs were not considered a substantial reproduction of ANI’s news articles.
Background of the Dispute
ANI Media filed a lawsuit against OpenAI, arguing that OpenAI had copied and stored ANI’s copyrighted news articles for training its LLMs without a license and that ChatGPT had substantially reproduced portions of ANI’s articles. In response, OpenAI claimed that the Delhi High Court lacked jurisdiction as their servers and activities were outside India, that ANI’s content use was non-infringing under the ‘private’ use clause of Section 52(1)(a), and that ChatGPT’s outputs were summaries or paraphrases, not copies.
Key Court Findings
Territorial Jurisdiction
The court dismissed OpenAI’s argument against jurisdiction, stating that since ANI’s principal business location is Delhi and OpenAI offers services in India, Indian courts have territorial jurisdiction. The court emphasized that the location of servers could not shield OpenAI from Indian copyright laws when the alleged infringement impacts were felt domestically. The court ruled that contractual clauses stipulating dispute resolution outside India were irrelevant.
Interpretation of Fair Dealing
A critical aspect of the judgment was the interpretation of Section 52(1)(a), which exempts fair dealing for “private or personal use, including research” from copyright infringement. The court rejected ANI’s assertions that commercial operations of AI systems are automatically excluded from this exception. It clarified that the absence of a non-commercial requirement in Section 52(1)(a) permits commercial entities to claim this exemption. The court also expanded the definition of ‘private’ use to include corporations, stating that AI’s storage of ANI’s works qualified as ‘private’ use.
No Prima Facie Copyright Infringement
Addressing ANI’s claim that ChatGPT’s outputs infringed its copyright, the court found that ANI could not prove that its articles were used in OpenAI’s training data. The court concluded that ANI failed to demonstrate any memorization or replication of its works in ChatGPT’s responses, thus ruling out copyright infringement under Section 51 of the Copyright Act.
Implications of the Judgment
This ruling marks the first structured, factor-based assessment of fair dealing in the AI context by an Indian court. It suggests that copyright laws should adapt to technological advances while maintaining core principles. The judgment supports AI developers by recognizing AI training as potentially falling within ‘research,’ offering relief from immediate licensing pressure.
The decision, an interim order, leaves open several questions for further deliberation, including the lawful extent of AI training on copyrighted material. The final judgment in this case will likely influence India’s AI copyright framework significantly. This ruling will be closely observed internationally as it contributes to the evolving jurisprudence on AI and copyright.
About the Authors
Gaurav Bhalla is a Partner and Parag Singhal is a Senior Associate at Ahlawat & Associates.
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Disclaimer: The opinions expressed in this article are those of the author(s) and do not necessarily reflect the views of Bar & Bench.
