Key holding or allegation
At the interim stage the Delhi High Court held prima facie that storing publicly accessible ANI works for LLM training fell within section 52(1)(a) fair dealing for private use including research, and ANI had not established substantial reproduction or memorisation in the tested outputs.
Why it matters
Major 2026 Indian decision directly addressing AI training, fair dealing, RAG, memorisation and outputs.
Facts
ANI challenged OpenAI's alleged use/storage of news material for training and alleged reproduction through ChatGPT/RAG outputs.
Issues before the court
Whether training storage was prima facie fair dealing, whether outputs substantially reproduced protected expression, whether memorisation was shown and whether Indian courts had jurisdiction.
What the court did not decide
The court expressly limited its conclusions to the interim application; the main suit remains pending and the findings do not bind the final merits.
Procedural timeline
High Court of Delhi
Interim-injunction judgment: Court held prima facie that storing publicly accessible ANI works for LLM training fell within section 52(1)(a) fair dealing for private use including research and found insufficient proof of substantial reproduction/memorisation in tested outputs.
High Court of Delhi
Correction order: Court corrected paragraph 80 so the referenced U.S. authority was Kadrey v Meta rather than Bartz v Anthropic.