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Rules Training LLMs Is Under The Indian Copyright Act
In a significant verdict for the future of artificial intelligence in India, the has dismissed an application filed by Media Pvt. Ltd. () against Opco LLC (). The court ruled that the storage of copyrighted material for the purpose of training Large Language Models (LLMs) like ChatGPT qualifies as "" under .
A Technological Collision
The legal battle pitted a prominent news agency against a global leader in generative AI technology. alleged that ’s unauthorized scraping, storage, and reproduction of its literary works amounted to on two counts: the "training claim"—concerning the storage of data to teach the LLMs—and the "output claim," which asserted that the AI produced near-verbatim copies of their articles.
The Court’s Reasoning
Justice Amit Bansal, delivering the judgment, emphasized that copyright laws must adapt to technological disruptions. The court analyzed the functionality of LLMs, noting that ’s models are not designed to "memorize and regurgitate" content. Crucially, the court found that the illustrative news articles cited by —published after the training cutoff dates for the models—could not have been part of the training sets, thereby weakening the claim of verbatim memorization.
Regarding the "
" defense, the court offered a liberal, purposive interpretation of
, which protects
"private or personal use, including research."
The court applied the "
," ruling that research conducted by AI systems is no less valid than human research if it promotes scientific progress and societal benefit.
Key Observations
"The process of training LLMs underlying ChatGPT can be considered as a form of research for generating new knowledge and advancing artificial intelligence systems."
"Any granted at this stage would, in my opinion, be detrimental to the growth of AI and more particularly, to the LLMs being developed in India."
"This Court is not inclined to grant an at this stage. is also against grant of . would be caused not only to Open AI but also to the public at large."
The Impact on Innovation
Justice Bansal also highlighted the public interest factor, noting that the development of AI is essential for India’s competitive edge in the global market. The court observed that forcing LLM developers to negotiate individual licenses for every public data point would make AI development economically unviable. Furthermore, the court noted that had not proven that its market share was negatively impacted by ChatGPT, nor had it exercised its option to "opt-out" by using technological barriers like crawler blockers on its website.
The application for was dismissed, with the court stressing that the observational rulings were confined to the interim stage. This decision marks a milestone in Indian jurisprudence, establishing that, at least , the infrastructure of the AI revolution—data training—is shielded by the principles of .
