AI-Generated Content and Copyright in India – Who Is the Author?

A poem written by ChatGPT. A painting produced by Midjourney from a two-line prompt. A news article drafted by a large language model trained on millions of copyrighted sources. A film score composed entirely by an algorithmic system without a human composer touching an instrument. These are not hypothetical scenarios from a speculative future; they are daily commercial realities in India and across the world as of 2026, produced at scale, published without attribution and monetized without anyone having clearly resolved the most basic copyright question that each of them raises: who, if anyone, is the author?

The answer that Indian copyright law currently gives to this question is incomplete, structurally ambiguous and in urgent need of legislative resolution. The Copyright Act, 1957, was drafted in a world where every creative work was made by a human being, and its definitional architecture reflects that assumption so deeply that the Act does not once use the words “artificial intelligence,” “generative,” “machine learning,” or “algorithm.” What it does contain, inserted quietly by the Copyright (Amendment) Act, 1994, is a single sub-clause in the definition of “author” Section 2(d)(vi) that addresses “computer-generated works” and which now bears the enormous interpretive weight of determining whether AI-generated content can attract copyright protection in India at all and if so, in whose name. How far that sub-clause stretches, what its legislative history tells us about its intended scope, where it meets the absolute requirement of originality set by the Supreme Court in Eastern Book Company v. D.B. Modak (2008) 1 SCC 1 and how Indian courts and the Copyright Office have already begun to grapple with AI authorship in practice are the questions this article addresses in full.

The Statutory Definition of “Author” Under Section 2(d)

Any analysis of AI authorship in India must begin with and return repeatedly to the precise text of Section 2(d) of the Copyright Act, 1957, because it is the only provision in the Act that defines who an author can be and because the AI authorship question turns entirely on what that definition can and cannot accommodate.

Section 2(d) provides that “author” means, in relation to a literary or dramatic work, the author of the work; in relation to a musical work, the composer; in relation to an artistic work other than a photograph, the artist; in relation to a photograph, the person taking the photograph; in relation to a cinematograph film or sound recording, the producer; and the provision added in 1994 in relation to any literary, dramatic, musical or artistic work which is computer-generated, the person who causes the work to be created. This last sub-clause, Section 2(d)(vi), is the pivotal provision for AI copyright analysis. It establishes a category “computer-generated work” and designates a specific author for works in that category: “the person who causes the work to be created.” It does not define “computer-generated work” separately, and the Act contains no further elaboration of what “causes the work to be created” means in practice, how much human involvement that phrase demands or how it applies when the generative process involves a machine that operates autonomously beyond the specific instructions of any identifiable human.

The legislative history of Section 2(d)(vi) is instructive but limited in what it reveals about the provision’s intended scope. The 1994 amendment was directed principally at what might be called first-generation computer assistance software programs that produced output according to rules and parameters set entirely by a human programmer, such as database compilations, computer-aided design drawings and algorithmically generated financial reports. The legislature in 1994 was addressing the question of who owns the output of a computer program that a human has fully designed and controlled, not the question of who owns the output of a neural network that has been trained on billions of data points and generates novel content through processes that its own programmers cannot fully explain or predict. The conceptual distance between the computer programs of 1994 and the large language models, diffusion models and generative adversarial networks of 2024 is so vast that it is genuinely uncertain whether Section 2(d)(vi) was intended to or can reasonably be interpreted to cover the latter category at all.

The Originality Requirement – Eastern Book Company and the Human Creativity Threshold

Section 13(1)(a) of the Copyright Act, 1957, provides that copyright subsists in original literary, dramatic, musical and artistic works. The word “original” is the gatekeeper of the entire copyright system, and its meaning under Indian law was authoritatively settled by the Supreme Court in Eastern Book Company v. D.B. Modak, (2008) 1 SCC 1. The dispute concerned the copyright claimed by a law publisher in the edited versions of Supreme Court judgments that it published in its law reports, together with the headnotes and other editorial matter its editors added to the raw judgments. The Supreme Court held that originality under the Indian Copyright Act requires more than the mere investment of labour and capital, a “sweat of the brow” standard that the Court expressly rejected as insufficient. Originality requires the exercise of skill and judgment by the author, reflecting a degree of intellectual creativity that goes beyond mechanical reproduction of pre-existing material, even where that reproduction requires significant effort. A work produced by the simple application of a computer process to existing input data, without any creative intellectual choice made by a human being, does not meet this standard.

The Eastern Book Company’s originality standard has direct and serious consequences for AI-generated content. A generative AI system, by its nature, applies learned statistical patterns to input data to produce output. Whether that output process involves anything recognizable as “skill and judgment” in the sense the Supreme Court had in mind the creative intellectual choices of a conscious human author is precisely the question that remains unresolved. Courts in India have not yet directly applied the Eastern Book Company standard to AI-generated output, but the analytical framework is unambiguous in its direction: a work that is produced without any identifiable human exercise of creative skill and judgment cannot qualify as “original” for copyright purposes, regardless of how sophisticated the process that produced it appears to an external observer and regardless of how novel or aesthetically impressive the output may be.

The consequence is that even if Section 2(d)(vi) is interpreted broadly enough to assign authorship to a human user of an AI system, that assignment of authorship does not automatically confer copyright the work must independently satisfy the originality requirement of Section 13(1)(a), which requires that the human author’s contribution to the creation of the work reflects the exercise of skill and judgment. A user who types a single two-word prompt into Midjourney and receives a generated image has not exercised the kind of skill and judgment the Supreme Court identified as the basis of originality. A user who spends weeks crafting a detailed, specifically structured prompt, iterates through hundreds of generated versions, selects and modifies specific outputs and makes deliberate creative choices about composition, colour palette and subject matter at each stage of the process may be closer to satisfying that standard but no Indian court has yet drawn this line and the position remains deeply uncertain.

The RAGHAV Case – India’s First Encounter with AI Authorship Registration

The closest India has come to a directly decided case on AI copyright authorship is the RAGHAV affair, which remains technically unresolved but whose administrative outcome has clarified the Copyright Office’s current position with considerable force. Ankit Sahni, a lawyer and technology entrepreneur, developed an application called RAGHAV Robust Artificially Intelligent Graphics and Art Visualizer that used machine learning to generate visual artworks by analyzing stylistic patterns from input images. Using RAGHAV, Sahni created an artwork called “Suryast,” which rendered a photograph of a sunset in the style of Vincent van Gogh’s “Starry Night.” Sahni filed for copyright registration of Suryast and, in the application, listed RAGHAV as a co-author alongside himself. In November 2020, the Indian Copyright Office issued a registration for Suryast, recognising RAGHAV as a co-author making this, as commentators noted, potentially one of the first copyright registrations anywhere in the world to formally recognise an AI system as a co-author of a creative work.

The registration did not stand. The Copyright Office subsequently issued a withdrawal notice, stating that the recognition of RAGHAV as a co-author was inconsistent with the Copyright Act, 1957, which requires authorship to be attributed to natural or legal persons and does not permit the attribution of authorship to a software system or AI tool. The registration for Suryast remains listed as “Registered” on the Copyright Office’s online portal and the matter has not been formally adjudicated by any court. Sahni’s position, developed in submissions to intellectual property offices in India and other jurisdictions, was that RAGHAV functioned as an assistive tool under his creative direction and that his own oversight and selection process provided the human authorship required for copyright a position that, if accepted by a court, would place the case in the category of human-AI collaboration rather than pure autonomous AI generation and would assign copyright to Sahni as the human author using an AI tool rather than to the AI system itself.

The Copyright Office’s withdrawal of the co-authorship recognition, taken together with the administrative clarification that a human author is mandatory for copyright registration in India, establishes the current institutional position: the Copyright Office will not register copyright in a work that lists an AI system as an author and will require that any copyright application for AI-generated or AI-assisted content identify a natural or legal person as the author. This is an administrative position, not a judicial one and it remains subject to challenge. But it is the de facto governing standard for copyright registration practice in India until a court or legislature decides otherwise.

ANI v. OpenAI – The Training Data Question and India’s Foundational AI Copyright Dispute

The question of AI authorship of outputs is closely related to, but analytically distinct from, a second major copyright question raised by generative AI: whether the use of copyrighted works to train an AI system constitutes infringement of those works’ copyright. This second question is the subject of the most significant pending AI copyright litigation in India, ANI Media Pvt. Ltd. v. OpenAI Inc., CS(COMM) 1028/2024, filed before the Delhi High Court in November 2024 and still at an early procedural stage as of the current date.

Asian News International (ANI), one of India’s largest and most widely distributed news wire services, filed the suit alleging that OpenAI had used ANI’s copyrighted news articles including content behind paywalls to train ChatGPT and related large language models without authorization or compensation. ANI also alleged that ChatGPT had, on numerous occasions, reproduced ANI’s news content verbatim or near-verbatim in its responses to user queries and in some cases had fabricated news reports falsely attributed to ANI as a source, damaging ANI’s credibility as a news organization. The suit sought an injunction preventing OpenAI from using or reproducing ANI’s material and the removal of ANI content from OpenAI’s training datasets. Several other Indian media organizations including NDTV, Indian Express and Hindustan Times have sought to intervene in the proceedings as similarly aggrieved copyright owners.

OpenAI has defended the suit on two grounds. First, it has challenged the Delhi High Court’s territorial jurisdiction, arguing that its servers are not located in India and that no reproduction of ANI’s content within India has been demonstrated. Second, OpenAI has invoked the fair dealing provisions of Section 52 of the Copyright Act, 1957, arguing that the ingestion of published text for the purpose of training a large language model constitutes fair dealing for research purposes or that it constitutes a transformative use that does not infringe the copyright in the original works. OpenAI also disclosed that it had blocked ANI’s website in October 2024, ensuring that the domain would not be included in future training datasets a disclosure that the court noted without treating it as fully resolving the historical infringement claim.

The Delhi High Court has issued notice to OpenAI and the matter is proceeding through preliminary hearings. No final judgment has been delivered and no interim injunction has been granted as of the current date. The case is, however, the most consequential pending IP matter in India’s technology sector and its eventual resolution, whether by judicial decision or legislative intervention will establish whether India’s copyright framework treats the training of commercial AI systems on copyrighted content as infringement, as fair dealing, as requiring a compulsory licence mechanism or as requiring bespoke statutory treatment. The DPIIT had, in mid-2024, issued a clarification that commercial-scale use of copyrighted content for AI training is not protected by the fair dealing exception under Section 52, aligning India’s regulatory position with the EU’s approach under the EU AI Act and the Digital Single Market Directive, which distinguish between text and data mining for research purposes (which is permitted) and text and data mining for commercial profit-making AI development (which requires authorization). This DPIIT position is not a judicial or legislative determination, but it carries weight as the executive branch’s interpretation of existing law and will likely be relied upon by ANI in resisting OpenAI’s Section 52 defence.

The Section 2(d)(vi) “Computer-Generated Work” Question

The provision at the heart of the AI authorship debate, Section 2(d)(vi), is capable of at least three distinct interpretations when applied to the generative AI context, each of which produces different legal outcomes and each of which has received some support in academic commentary and comparative jurisprudence.

The first and narrowest reading is that Section 2(d)(vi) applies only to first-generation computer-generated works works produced by software programs that are entirely designed and controlled by an identifiable human programmer, where the computer executes a deterministic or rule-based process and has no generative capacity of its own. On this reading, a spreadsheet report generated by a macro written by an accountant or a computer-aided design drawing generated by an engineering software tool under the precise direction of an engineer falls within Section 2(d)(vi), with the programmer or operator being “the person who causes the work to be created.” A work generated by a large language model through a process of probabilistic pattern-matching across billions of training parameters falls outside this provision entirely, because there is no identifiable person whose creative choices determined the specific output and the generative process is so far removed from human authorial control that calling any human “the person who causes the work to be created” stretches the phrase beyond its natural meaning.

The second and broader reading treats Section 2(d)(vi) as deliberately flexible as drafted to accommodate future generations of computer technology that Parliament in 1994 could not specifically foresee. On this reading, “computer-generated work” encompasses any work produced by any computer system, including AI and “the person who causes the work to be created” is whoever initiated the generative process, the developer of the AI model, the user who entered the prompt, or both jointly. This reading aligns Section 2(d)(vi) with the UK approach under Section 9(3) of the Copyright, Designs and Patents Act, 1988, which designates as the author of a computer-generated work “the person by whom the arrangements necessary for the creation of the work are undertaken.” The UK provision was enacted in the same legislative tradition and addresses the same conceptual problem. If the Indian courts adopt this broader reading, the likely outcome is that copyright in AI-generated content vests in the human operator of the AI system the prompt engineer, the user as the person most immediately causing the specific work to be generated, subject always to the independent requirement of originality under Section 13(1)(a).

The third reading, which no Indian court has yet adopted but which finds support in academic literature and in the US Copyright Office’s position, holds that the nature of generative AI output is so fundamentally different from either traditional human authorship or first-generation computer-generated works that it falls into a gap that Section 2(d)(vi) simply does not address. On this reading, truly autonomous AI-generated content produced by a model that exercises its own probabilistic creative processes in response to a minimal human prompt falls outside the scope of copyright protection entirely because it satisfies neither the human authorship requirement implied throughout the Act nor the originality requirement of Section 13(1)(a). The output falls into the public domain from the moment of its creation. This outcome may seem commercially undesirable for the AI industry and for users who invest in AI tools, but it reflects the honest application of a human-centred copyright framework to a category of creation for which that framework was not designed.

The Originality Spectrum – From Pure AI to Human-AI Collaboration

The three readings above represent positions at opposite ends of a spectrum. In practice, most commercially significant AI-generated content sits somewhere along that spectrum rather than at either extreme. Understanding where on the spectrum any particular work sits is the practical task that courts, copyright practitioners and the 2025 expert panel will need to resolve and three categories can be provisionally identified for analytical purposes.

At one end is what might be called pure AI output, a work generated entirely by an AI system in direct response to a minimal, content-free prompt, where the human contribution is limited to switching the system on and choosing from multiple generated options. An image generated by typing “sunset” into an image generation tool is a plausible example. For such a work, the case for copyright protection under current Indian law is weakest because the human contribution is minimal, the AI system’s autonomous generative process dominates the creative output and no exercise of skill and judgment by any identified human author can be cleanly attributed to the specific work produced. The Copyright Office’s refusal to register AI systems as authors, combined with the Eastern Book Company originality standard, makes such works highly vulnerable to a finding that they attract no copyright protection at all under the current Act.

At the other end is what might be called AI-assisted human creativity a work in which a human author uses AI as a sophisticated tool, making detailed, specific and intellectually significant creative choices at every stage of the production process. An author who uses a large language model to generate draft text, then substantially edits, restructures and rewrites that text to reflect their own intellectual and creative choices, exercises skill and judgment over the final output in a manner that may satisfy the Eastern Book Company standard. A visual artist who uses AI to generate initial compositional options, then modifies specific elements, adjusts colours, adds original details and makes deliberate aesthetic decisions about the final work is similarly positioned. For such works, the case for copyright in the name of the human author is reasonably strong under current law and the Section 2(d)(vi) designation of “the person who causes the work to be created” can plausibly be applied to that human author as the directing intelligence behind the specific creative output.

In the middle is a genuinely contested category: AI output generated from detailed, substantive prompts that reflect significant intellectual effort and creative choice by the human prompt-author, but where the AI’s own generative capacity contributes substantially to the specific form, expression and content of the output. A lawyer who spends three hours crafting a detailed, carefully structured prompt specifying the genre, tone, thematic content, narrative arc, character development and stylistic approach of a short story and who receives a story that fully realizes those specifications, has exercised considerably more creative effort and judgment than the person who types “sunset.” Whether that effort amounts to the authorial skill and judgment the Supreme Court required in Eastern Book Company and, therefore, whether copyright vests in the human prompt-author, is a question that no Indian court has yet decided.

The Ownership Question – Section 17 and Corporate AI Users

Even if authorship can be established in a human person, the separate question of copyright ownership under Section 17 of the Copyright Act, 1957, requires examination in the AI context. Section 17 provides that the author of a work is the first owner of the copyright in it, subject to certain exceptions. The most commercially significant exception for the AI context is the work-for-hire rule: where a work is made by an author in the course of their employment under a contract of service or apprenticeship, the employer, not the author-employee, is the first owner of the copyright, in the absence of any agreement to the contrary. A software engineer employed by a technology company who develops an AI system that generates copyrightable content in the course of their employment will have transferred first ownership of both the software and any applicable rights in AI-generated outputs to their employer under this provision. Similarly, where an organisation employs a team of data scientists, prompt engineers and content specialists to develop and operate a generative AI content pipeline, the copyright in the outputs, to the extent it exists at all will vest in the organization as employer rather than in any individual employee whose creative contributions fed into the process.

The terms of service agreements of commercial AI platforms add a further contractual layer. OpenAI’s terms of service, for example, assign ownership of AI-generated outputs to the user who generated them, to the extent that any copyright subsists in those outputs. Midjourney’s terms similarly assign rights to users in certain circumstances. These contractual assignments operate independently of the underlying copyright law and do not by themselves create copyright where the Act does not provide for it a contractual term asserting that a user “owns” AI-generated content does not make that content copyrightable if Indian law treats it as not protected, but they do resolve the ownership question between the platform and the user for content that does attract copyright protection.

The Expert Panel, the DPIIT Clarification and the Reform Trajectory

The Government of India’s response to the AI copyright challenge has moved on two tracks simultaneously: regulatory clarification through existing executive mechanisms and consideration of legislative reform through the Ministry of Commerce and Industry’s 2025 expert panel.

On the regulatory track, the DPIIT issued a clarification in mid-2024 stating that the commercial use of copyrighted content for AI training is not protected by the fair dealing exception under Section 52 of the Copyright Act, 1957. This clarification has significant practical implications for the ANI v. OpenAI litigation and for the broader landscape of AI training practices in India it signals that the executive branch regards AI training on copyrighted material without authorisation as potentially infringing and rejects the broad text-and-data-mining exception that some AI developers have sought to establish. MeitY’s March 2024 advisory on due diligence by intermediaries under the Information Technology Act, 2000, also imposed obligations on AI platforms regarding content labelling, the handling of AI-generated content and reporting requirements for the deployment of AI systems that generate synthetic content establishing a regulatory dimension to AI content governance that sits alongside and partially overlaps with the copyright law framework.

On the legislative track, the Ministry of Commerce and Industry constituted an eight-member expert panel in May 2025 to evaluate whether the Copyright Act, 1957, adequately addresses the challenges presented by generative AI. The panel is the most significant formal Indian government response to the AI copyright problem and its preliminary deliberations have been widely reported, though no final report has been published as of the current date. Among the options under discussion are the introduction of a new chapter in the Act potentially Chapter XII-A specifically addressing AI-generated works, clarifying the scope of “computer-generated works” under Section 2(d)(vi) in the AI context, establishing a “significant human input” test for copyright protection of AI-assisted works and introducing a specific text-and-data-mining exception or compulsory licensing mechanism for the use of copyrighted content in AI training. These proposals reflect a serious and substantive engagement with the core questions this article raises and their eventual legislative implementation will transform the current uncertainty into a settled if inevitably imperfect statutory framework.

Comparative International Context – The UK, the US, China and the EU

India is not navigating this uncertainty in isolation. Every major copyright jurisdiction in the world is confronting the same set of questions, and the comparative landscape offers three distinct legislative models that the Indian expert panel is evaluating.

The United Kingdom enacted the world’s first statutory provision specifically addressing computer-generated works in Section 9(3) of the Copyright, Designs and Patents Act, 1988, which designates as the author of such works “the person by whom the arrangements necessary for the creation of the work are undertaken.” This provision deliberately anchors AI-generated work copyright in a human who organised and directed the generative process and gives that work a reduced term of protection (fifty years rather than the standard author’s lifetime plus seventy years). The UK Intellectual Property Office has been conducting consultations on whether Section 9(3) adequately addresses generative AI specifically, recognizing that the 1988 provision was drafted for deterministic computer programs rather than for probabilistic generative models.

The United States Copyright Office has taken the firmest human-authorship position of any major jurisdiction, holding in its policy documents and in the Zarya of the Dawn case concerning AI-generated comic book art that copyright will only subsist in those elements of a work that can be attributed to human authorship. Purely AI-generated elements receive no protection; elements that reflect genuine human creative selection, arrangement or expression within an AI-assisted work may be protected to the extent of that human contribution. The US position does not provide a bright line between sufficient and insufficient human contribution it requires case-by-case assessment, but it makes clear that a human’s act of prompting an AI system does not, by itself, establish the authorship needed for copyright in the AI’s output.

China has taken the most AI-friendly approach of any major jurisdiction. Chinese courts most notably in the 2023 case concerning an AI-generated image in which a Beijing court held that an image produced by the Stable Diffusion model in response to a user’s detailed creative choices attracted copyright protection as the user’s original work have been more willing than their counterparts elsewhere to find that the human prompt-author’s intellectual contribution to AI-generated output is sufficient for copyright, particularly where the prompt reflects detailed and specific creative input. This approach is closer to the “broad reading” of Section 2(d)(vi) discussed above and represents the most commercially accommodating position for AI-generated content within the copyright framework.

The European Union AI Act, 2024, addresses AI-generated content primarily from the perspective of transparency and risk management rather than copyright ownership, requiring that AI-generated content be labelled as such and imposing obligations on operators of high-risk AI systems but it does not resolve the copyright authorship question, which remains governed by national copyright laws across EU member states with varying approaches.

The Public Domain Consequence – Why Unresolved Uncertainty Is Itself Costly

One consequence of the current legal uncertainty that deserves specific attention is the risk that AI-generated content in India simply falls into the public domain by default that it is neither protected by copyright vesting in any identifiable person, nor specifically placed in the public domain by legislative act, but simply exists without any copyright because no court has confirmed that it attracts protection and no legislature has said that it does not. This consequence is commercially significant for three reasons.

First, if AI-generated content is unprotected, then any person can reproduce, adapt and commercially exploit any AI-generated content created by anyone else, without payment or authorization. The business models of AI content companies, news aggregators using AI to generate articles, creative agencies using AI to produce advertising content,and software companies using AI to write code rest on the assumption that the AI-generated outputs they produce for clients attract copyright protection. If that assumption is wrong under Indian law, those business models are substantially undermined because competitors can freely copy the output without infringing any right.

Second, if AI-generated content is unprotected, then the content itself cannot be the subject of an exclusive licence, an assignment or a security interest, because these transactions all require an identifiable right-holder. Contracts that purport to assign “copyright” in AI-generated content would be assigning something that does not exist, with potentially significant consequences for content transactions across the creative industries.

Third and perhaps most importantly from a policy perspective, if genuinely autonomous AI-generated content falls into the public domain while AI-assisted human creative work retains full copyright protection, then the economic incentive structure of the copyright system pushes content producers toward establishing and documenting the human creative contribution to every AI-assisted work, regardless of how minimal that contribution actually was. This is a compliance burden that serves no genuine creative policy purpose and creates perverse incentives to artificially inflate apparent human authorship.

Conclusion

The question “who is the author of AI-generated content in India?” has, as of mid-2026, no clean statutory answer, no settled judicial answer and no final regulatory answer. What India does have is a statutory provision Section 2(d)(vi) that was drafted for a different technological context but which contains language flexible enough to support multiple readings; an originality standard from Eastern Book Company that demands human creative skill and judgment and sits uneasily with the autonomous generative processes of modern AI; a Copyright Office that has effectively required human authorship for registration without resolving the harder questions about what degree of human involvement suffices; an ongoing case ANI v. OpenAI that addresses the related but distinct question of AI training data and that will shape how Indian courts approach generative AI in the copyright context; a DPIIT regulatory position that rejects fair dealing as a defence for commercial AI training; and a Ministry of Commerce expert panel that has acknowledged the inadequacy of the current law and is actively evaluating legislative reform.

The trajectory of that reform, when it arrives, will need to resolve at minimum the following questions with statutory precision: whether “computer-generated work” in Section 2(d)(vi) encompasses generative AI output; what degree of human contribution to an AI-assisted work is sufficient to constitute the originality required by Section 13(1)(a); whether the Copyright Act should introduce a reduced-term sui generis right for AI-generated content analogous to the UK model, distinct from full copyright; whether a text-and-data-mining exception or compulsory licensing mechanism should be introduced for AI training; and what disclosure and labelling obligations should apply to AI-generated content placed in commercial circulation. Until those questions are resolved by the courts in the ANI v. OpenAI proceedings, by the expert panel’s legislative recommendations or by some combination of both, Indian copyright law will continue to give an incomplete, contextually dependent answer to the most fundamental creative question of our technological moment: when a machine creates, who made it?

References

1. Copyright Act, 1957 (as amended) Section 2(d), Section 13, Section 17, Section 52 – https://copyright.gov.in/Documents/CopyrightRules1958.pdf
2. Eastern Book Company v. D.B. Modak, (2008) 1 SCC 1 – https://main.sci.gov.in/judgment/judis/29615.pdf
3. ANI Media Pvt. Ltd. v. OpenAI Inc., CS(COMM) 1028/2024, Delhi High Court – https://delhihighcourt.nic.in
4. RAGHAV AI Co-Authorship Case – Indian Copyright Office, 2020 – https://copyright.gov.in
5. DPIIT Clarification on AI Training and Fair Dealing, 2024 – https://dpiit.gov.in
6. MeitY Advisory on Intermediary Due Diligence and AI, March 2024 – https://www.meity.gov.in
7. Ministry of Commerce Expert Panel on Copyright Act and AI, constituted May 2025 – https://dpiit.gov.in
8. WIPO – Conversation on AI and Intellectual Property – https://www.wipo.int/about-wipo/en/offices/singapore/events/2024/wipo_conversation_ip_ai.html
9. UK Copyright, Designs and Patents Act 1988 – Section 9(3) – https://www.legislation.gov.uk/ukpga/1988/48/section/9
10. US Copyright Office – Copyright and Artificial Intelligence Report, 2025 – https://www.copyright.gov/ai/
11. EU Artificial Intelligence Act, 2024 – https://artificialintelligenceact.eu
12. Berne Convention for the Protection of Literary and Artistic Works – https://www.wipo.int/treaties/en/ip/berne/

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