Delhi High Court: OpenAI's ChatGPT Training Data Not Infringing Copyright

• Delhi High Court declined to grant ANI Media an interim injunction against OpenAI, holding that LLM training falls under 'private or personal use, including research'.
• Court's reasoning on territorial jurisdiction and fair dealing may shape how Indian courts approach copyright disputes involving large language models.
• Ruling has significant implications for AI developers, publishers, and Indian courts, highlighting the need for clearer guidelines on fair dealing and territorial jurisdiction.

The court declined to grant ANI Media an interim injunction against OpenAi, holding that process of training LLMs undertaken by Open Ai using stored literary work of ANI falls, prima facie, under 'private or personal use, including research' as provided in Section 52(1)(a) of the Copyright Act, 1957.

On July 24, 2026, Justice Amit Bansal of the Delhi High Court delivered an interim judgment in ANI Media v. OpenAI that may have significant implications for the use of large language models (LLMs) in India. The court declined to grant ANI Media an interim injunction against OpenAI, holding that the process of training LLMs undertaken by OpenAi using stored literary work of ANI falls under 'private or personal use, including research' as provided in Section 52(1)(a) of the Copyright Act, 1957. This ruling suggests that Indian courts may adopt a more lenient approach to copyright infringement claims involving AI-generated content. The court's reasoning on territorial jurisdiction and fair dealing will likely shape how AI developers and publishers navigate training data and generative outputs in India.

The Delhi High Court's ruling is significant because it applies the concept of 'private or personal use, including research' under Section 52(1)(a) of the Copyright Act, 1957 to the training of LLMs. This provision allows for fair dealing in certain circumstances, but its application to AI-generated content has been unclear until now. The court's decision may set a precedent for how Indian courts approach copyright disputes involving large language models and their training data. Lawyers advising clients on AI-generated content should pay close attention to the Delhi High Court's reasoning on territorial jurisdiction and fair dealing.

The Delhi High Court's interim ruling has significant implications for AI developers, publishers, and Indian courts. The court's decision may shape how companies approach the use of training data and generative outputs in India. AI developers and publishers should be aware that Indian courts may adopt a more lenient approach to copyright infringement claims involving AI-generated content. This ruling also highlights the need for clearer guidelines on fair dealing and territorial jurisdiction in the context of large language models.

Lawyers advising clients on AI-generated content should watch for the Delhi High Court's reasoning on territorial jurisdiction and fair dealing, which may shape how Indian courts approach copyright disputes involving large language models.

Source: Original reporting via ANI Media v. Open AI Opco LLC [CS(COMM) 1028/2024]