India's Copyright Office has ruled that AI-generated works may qualify for copyright protection, but an AI system itself cannot be recognized as the legal author under the Copyright Act, 1957. The order, passed on August 31 by Registrar of Copyrights Prof. ) Unnat P Pandit, came in response to an application by US AI researcher Stephen Thaler, who sought copyright registration for an artwork created by his AI system, DABUS.

The artwork, titled "A Recent Entrance to Paradise," was generated by DABUS, short for Device for the Autonomous Bootstrapping of Unified Sentience. In his application, Thaler listed DABUS as the author and himself as the copyright owner. He argued that the artwork was produced by the AI system without any real-time human intervention or text prompt, after the system was trained using photographs, thesaurus entries, and English sentences provided by him.

The Ruling

The Copyright Office rejected Thaler's application, saying Indian law recognizes a human being as the author of a copyrighted work. "The law distinguishes between the technological mechanism through which the output is generated and the legally recognised person to whom authorship is attributed," the office said.

The office cited Section 2(d)(vi) of the Copyright Act, which defines the author of a computer-generated artistic work as the "person who causes the work to be created." The Registrar said DABUS is neither a natural person nor a legal entity recognized under Indian law, and therefore cannot qualify as an author.

The order noted that Thaler had designed, configured, and trained the system and provided the material used in the process, making him the person who caused the work to be created. It further stated, "The fact that a system operates autonomously after being configured does not alter the identity of the person responsible for bringing the work into existence" and "Autonomy in execution is not synonymous with conception of a work."

Originality Upheld

While rejecting AI authorship, the Copyright Office ruled in Thaler's favor on originality. Registrar Pandit held that the standalone artwork can be considered "original" as there is "no clear material on record to prove that the work was copied from some specific source or some other work." He said it "possesses sufficient independently generated expressive character to cross the limited threshold."

The office said an AI-generated work can still meet the test of originality under Section 13 of the Copyright Act, and that the use of algorithms or computer processes alone does not make a work unoriginal.

The office also rejected a fallback request to record DABUS as the technological generator of the artwork. During the proceedings, the office had allowed Thaler to amend the application and name himself as the author, but he declined and continued to maintain that DABUS was the sole author.

Thaler argued that DABUS should be attributed as the sole author, not to give the AI system legal personality or independent enforceable rights, but to accurately record how the artwork was created. "Transparency requires the Register to reflect the actual mode of creation," he said.

Legal Context

The decision comes months after the Delhi High Court in April directed the Copyright Office to decide on whether an AI system can claim sole authorship over a work created using the system. The order is among the first in India to address the question of authorship in AI-generated works.

The order leaves open the possibility of a future application that identifies the author under the Copyright Act, and states that any broader change in the law would have to come from Parliament.

In other countries, such as the United Kingdom and Ireland, authorship is clearly associated with the human persona, or with the person who made the necessary arrangements for a computer-generated work. In 2019, a Chinese court ruled in favor of Tencent's ownership over content written by its AI-writing assistant Dreamwriter. In another case in 2023, a court in China held that AI-generated images reflecting people's original intellectual investment should be recognized as works protected by copyright law, but clarified that an artificial intelligence model cannot be deemed an author under China's copyright law.