Delhi High Court rules OpenAI training on ANI content constitutes fair dealing

The Delhi High Court refused an interim injunction sought by ANI against OpenAI, holding that storing ANI’s literary works for training large language models falls under the fair dealing exception in Section 52 of India’s Copyright Act for research purposes. The court found no prima facie evidence of memorization or substantial similarity in ChatGPT outputs and emphasized public interest in AI services. This is the first detailed Indian judicial treatment of generative AI training under copyright law.