From Libraries To Large Language Models: The New Meaning Of "Research"

1. Introduction

On 24 July 2026, the Hon’ble Delhi High Court declined to grant ANI Media Pvt. Ltd. (“ANI”) an interim injunction against OpenAI OPCO LLC (“OpenAI”) in ANI Media Pvt. Ltd. v. OpenAI OpCo LLC, ¹ making it the first substantial Indian ruling on whether training a generative AI model on copyrighted material infringes copyright. Central to that outcome was the Court's prima facie finding that OpenAI's storage of ANI's news content to train the large language models (“LLMs”) underlying ChatGPT fell within the fair dealing exception under Section 52(1)(a) of the Copyright Act, 1957. While the judgment addressed several issues, one its most intriguing aspect was the expansive interpretation of “research”, a term introduced in the statute in 1957, to now accommodate a technology that the legislature could not have imagined at that point in time. This article traces and analyses that reasoning.