CLAT-2027 Blog

Delhi HC: OpenAI Training ChatGPT on ANI Content is ‘Fair Dealing’, Not Infringement

CURRENT AFFAIRS | 25 JULY 2026

On 24 July 2026, the Delhi High Court (Justice Amit Bansal) held, in a prima facie interim ruling, that OpenAI’s storage and use of ANI’s copyrighted works to train its large language models amounts to “fair dealing” under Section 52(1)(a) of the Copyright Act, 1957 — and is not infringement. The Court found that ChatGPT’s RAG-generated outputs were not substantially similar to ANI’s originals, and that training is an internal process not shared with third parties. It is the first substantive Indian court finding on whether AI firms can train LLMs on copyrighted news content without a licence — squarely in CLAT’s legal-reasoning wheelhouse.

Legal Framework

The dispute turns on the Copyright Act, 1957. Section 52 lists acts that do not constitute infringement; Section 52(1)(a) is the fair-dealing exception. The Court read AI training as an internal, transformative use whose outputs were not substantially similar to the source — a reasoning pattern CLAT loves to test through principle-fact application.

Why This Matters for CLAT

This is prime legal-reasoning material on fair dealing, IP, and emerging tech. A passage may hand you the ‘fair dealing’ principle and ask you to apply it to new AI facts. Remember the anchors: Justice Amit Bansal, Section 52(1)(a), RAG outputs not substantially similar, prima facie interim.

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Key Facts at a Glance

Case ANI Media Pvt Ltd v OpenAI Inc & Anr
Court Delhi High Court
Judge Justice Amit Bansal
Date 24 July 2026
Finding Fair dealing — not infringement
Provision Section 52(1)(a), Copyright Act, 1957
Key reason RAG outputs not substantially similar
Nature Prima facie interim ruling

Memory Hook

“FAIR DEALING = FIFTY-TWO(1)(a).” Picture a fair judge (Bansal) dealing cards labelled 52(1)(a): training an AI is like reading a library book internally — so long as the output isn’t a copy, it’s fair dealing, not infringement.

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