Delhi High Court rules OpenAI's AI training doesn't breach ANI copyright in landmark case

Delhi High Court Denies ANI's Interim Copyright Relief Against OpenAI

The Delhi High Court on Friday delivered a significant ruling in the ANI vs OpenAI copyright dispute, denying interim relief to Asian News International in its copyright infringement lawsuit against the company behind ChatGPT1

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. Justice Amit Bansal held that ANI had failed to establish a prima facie case warranting an interim injunction, marking a critical moment in the debate over AI companies use of copyrighted content2

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ANI filed the suit in November 2024, alleging that OpenAI reproduced its copyrighted news reports without permission and that ChatGPT generated inaccurate responses attributed to the news agency, causing reputational harm1

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. OpenAI denied these allegations, arguing its use was transformative and did not constitute copyright infringement1

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Court Finds OpenAI's Storage Falls Under Fair Dealing Exception

In a detailed analysis, the court examined whether AI training on copyrighted material violates India's Copyright Act. Justice Amit Bansal observed that OpenAI's act of storing ANI's original works falls under Section 52(1)(a) of the Copyright Act and therefore does not amount to infringement under Section 5. The fair dealing exception for research purposes proved central to the ruling, as the court determined that OpenAI's storage of ANI's news articles to train the Large Language Models (LLMs) underlying ChatGPT is protected by this statutory provision3

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The court further held that outputs generated by ChatGPT do not amount to copyright infringement under Section 51, since responses generated by AI models were not substantially similar to ANI's content1

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. Addressing ANI's specific allegations about memorization, Justice Bansal stated that ANI failed to satisfy the court that any memorization or regurgitation of ANI's work had occurred from ChatGPT's responses2

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Balance of Convenience Favors OpenAI and Public Interest

Beyond the legal merits, the Delhi High Court considered the broader implications of granting interim relief. Justice Bansal observed that irreparable injury would be caused not only to OpenAI but also to the public at large if an interim injunction were granted in favor of ANI1

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. This consideration of public interest signals the court's awareness of how restrictions on AI development could affect technological progress and access to AI services.

First Substantive Judicial Finding on AI Training in India

The ruling represents the first substantive court finding in India on whether AI companies can train large language models on copyrighted news content without obtaining a license3

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. While the court decided only the interim injunction application and the main suit will continue, its findings provide the clearest indication yet of how Indian courts may approach questions around AI training under existing copyright law1

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This case mirrors a growing wave of litigation in the United States and Canada, where publishers, authors, and news organizations have sued OpenAI and other AI companies over similar issues3

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. However, unlike several US cases, the Delhi High Court expressly relied on India's statutory fair dealing exception, creating a potentially distinct legal precedent for the region1

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Implications for Indian Publishers and AI Industry

For India's news industry, the outcome extends beyond ANI alone. The case has drawn interventions from the Digital News Publishers Association and the Federation of Indian Publishers, indicating widespread concern among Indian publishers about how AI companies access and use their content1

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. The final judgment could shape the relationship between AI companies and content creators, while influencing future copyright disputes involving generative AI training across the country1

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As the main suit continues, stakeholders across the AI and media industries will watch closely to see whether the court's prima facie views hold in the final determination, and what this means for licensing negotiations between AI companies and content providers in India's rapidly evolving digital landscape.