Delhi High Court Examines Copyright Protection in AI-Generated Song Dispute

Summary

In a significant development at the intersection of artificial intelligence and copyright law, the Delhi High Court in Tarun Chaudhary & Anr vs. Kuldeep Meena & Ors.¹ addressed the complex question of whether copyright can subsist in a song generated using an AI tool.

The Court refrained from granting interim relief and highlighted the uncertainty surrounding authorship and ownership of AI-generated works under the Copyright Act, 1957.

Recognizing the novelty of the issue, the Court impleaded the Registrar of Copyright to assist in determining whether such works are capable of copyright protection under existing law.

Facts of the Case

The plaintiffs claimed ownership over a song titled “Teri Yaadon Ki Chadar Odhe”, asserting that the rights were acquired through a purchase agreement from the original creator.

However, it was admitted in the plaint that the musical composition of the song was generated using an AI tool known as SUNO AI, with only the lyrics being human-authored.

Reliefs Sought by the Plaintiffs

The plaintiffs sought multiple reliefs, including:

• Permanent injunction against infringement
• Removal of the song from platforms
• Disclosure of revenues
• Damages amounting to ₹2.5 crore

Defendants’ Argument

The defendants challenged the maintainability of the suit, arguing that no copyright could subsist in AI-generated music, particularly when the AI tool itself disclaimed any ownership or warranty over generated outputs.

Issues Before the Court

Whether copyright can subsist in a song generated using an AI tool, and whether the plaintiff can claim ownership over such a work under the existing framework of the Copyright Act, 1957.

Findings of the Court

The Court undertook a preliminary examination of the statutory framework, particularly Sections 2(d), 13, and 14 of the Copyright Act, 1957.

While Section 2(d) recognizes the “author” of a computer-generated work as the person who causes the work to be created, the Court noted that the present case raises a deeper question regarding the extent of human involvement required.

Key Observations

The Court observed that:

• The plaintiffs failed to clearly establish the nature and extent of copyright claimed, especially in relation to the AI-generated musical composition.
• The claim was not limited to the lyrics (which could qualify as a literary work), but extended to the entire song, including the AI-generated music.
• The terms of service of the AI tool indicated that no copyright ownership or warranty was guaranteed over generated outputs.

International Jurisprudence

The Court also took note of international jurisprudence, including the decision in Stephen Thaler vs. Shira Perlmutter (US Case), which emphasized the requirement of human authorship for copyright protection.

Given these uncertainties, the Court found itself confronted with a “piquant situation” regarding the applicability of copyright law to AI-generated works.

Held

The Court declined to grant an ex-parte ad-interim injunction, holding that it could not be prima facie satisfied about the plaintiff’s copyright in the AI-generated song.

To address the legal ambiguity, the Court impleaded the Registrar of Copyright as a necessary party and directed further proceedings to determine whether such works are entitled to copyright protection under Indian law.

Conclusion

This order marks an important step in the evolving discourse on AI and intellectual property in India. By refusing interim relief and seeking institutional clarity, the Delhi High Court has underscored the inadequacy of existing legal frameworks in addressing AI-generated content.

The case highlights the pressing need for legislative and judicial clarity on issues of authorship, ownership, and originality in the age of artificial intelligence. It also signals judicial caution in extending traditional copyright protections to technologically generated works without clear statutory backing.