The Delhi High Court held that OpenAI’s use of ANI Media’s copyrighted news content for training ChatGPT’s LLMs is prima facie protected under fair dealing provisions of the Copyright Act and declined interim injunction. A Single Judge Bench of Amit Bansal, J., held that OpenAI’s storage of ANI’s literary works for training fell within Section 52(1)(a) of the Copyright Act, 1957, qualifying as “private or personal use, including research” and satisfying fair dealing because it was limited to training, did not result in market substitution, and furthered public interest in technological innovation. The Court further held that ANI failed to establish memorisation, regurgitation, or substantial reproduction of its works through ChatGPT outputs. ANI had alleged copyright infringement on two fronts: the training claim (copying and storage for AI model training) and the output claim (generation of outputs reproducing ANI’s expression). The Court noted the dispute presented a novel challenge from rapid AI advances, requiring interpretation of the Copyright Act in an unforeseen technological context. The Court declined to grant interim injunction, holding that ANI failed to establish a prima facie case and that balance of convenience and irreparable injury weighed against relief.