The rise of Artificial Intelligence (AI) has introduced new challenges in the realm of copyright law, particularly concerning the ownership of works generated by AI systems. In India, the Copyright Act, 1957, is premised on human authorship, making it unclear how AI-generated works fit within the existing legal framework.

This article examines the legal and policy issues surrounding AI and copyright ownership in India, focusing on whether AI-generated works qualify for copyright protection and who should be considered the rightful owner-the AI developer, user, or the machine itself. Drawing on international precedents from the UK, the US, and the European Union, the article identifies gaps in Indian law and offers policy recommendations for future legislative reforms.

These include amending the Copyright Act to recognize AI-related works, creating a licensing framework, and clarifying the role of human involvement in AI-generated creations. By addressing these issues, India can ensure its copyright regime remains relevant in the era of AI-driven creativity.

Introduction
Artificial Intelligence (AI) is rapidly transforming creative industries, producing everything from music and art to literature and software with minimal human intervention. As these AI systems advance, they challenge traditional notions of authorship and copyright ownership, sparking debates about the legal status of AI-generated works. In India, the Copyright Act, 1957, forms the basis of intellectual property protection but is grounded in the assumption that a human creator is behind any copyrighted work. This raises critical questions: Can works created solely by AI systems be eligible for copyright protection? If so, who would own the rights—the AI developer, the user, or the machine itself?

India's current copyright laws do not provide clear answers to these questions. The law focuses on protecting "original" works, typically requiring human creativity and authorship. However, AI systems, especially those that employ machine learning and neural networks, can now generate outputs independently of human creators, complicating the definition of originality and authorship.

Globally, there is no consensus on how to address copyright for AI-generated works. The United States and the European Union have maintained that human authorship is a requirement for copyright protection, while countries like the UK have taken a more flexible approach by assigning copyright to the individual who arranges for the creation of a work by a machine. As India continues to embrace AI across various sectors, the need for clarity on copyright ownership is becoming increasingly urgent, demanding legal reforms to address the unique challenges posed by AI-generated works.[1]

This article explores the legal complexities surrounding AI and copyright ownership in India. It analyses the limitations of the current legal framework, reviews international developments, and offers policy recommendations for addressing the growing role of AI in creative processes. As AI technology advances, India must adapt its copyright laws to strike a balance between fostering innovation and protecting intellectual property rights.

Understanding Copyright Law In India:

India's copyright law is primarily governed by the Copyright Act, 1957, and subsequent amendments, most notably the Copyright (Amendment) Act, 2012. The Act provides protection for original literary, artistic, dramatic, musical, and cinematographic works, as well as sound recordings and computer programs. Copyright is granted to the author or creator of an original work, giving them the exclusive right to reproduce, distribute, and modify the work, among other rights.[2] However, the Act's language focuses on human authorship, which raises challenges in the context of works generated by Artificial Intelligence (AI).

Key Provisions of the Copyright Act, 1957

The Copyright Act defines an "author" as the person who creates the work.[3] For literary, dramatic, and musical works, the author is typically the person who has conceived the work. In the case of photographs, the person who captures the image is regarded as the author. Similarly, for cinematograph films, the producer is considered the author. This clear attribution of authorship assumes that the creator is always a human being.

One of the central tenets of copyright law in India is the requirement of originality. Section 13 of the Act states that copyright subsists in original works, which has been interpreted to mean that the work must originate from the author and involve a minimal level of creativity.[4] This interpretation, supported by Indian judicial precedents, further complicates the attribution of copyright to works generated by AI, as machines lack the conscious intent or creativity associated with human creators.

Copyright in Works Created by AI

The rapid evolution of AI technology has led to the creation of works with minimal or no human intervention, such as music compositions, paintings, and literary texts generated by machine learning algorithms. Indian copyright law, however, does not currently address how to handle such works. Since the Act's definition of an author relies on human creativity, works generated entirely by AI do not fall neatly within the scope of copyright protection.

The question of whether AI can be considered an author or hold copyright is unsettled in India. Globally, this issue has sparked debates, with some countries introducing provisions to address AI-generated works. For instance, UK copyright law includes provisions for computer-generated works, granting authorship to the person who made the arrangements necessary for the creation of the work.[5] Indian law, however, lacks such provisions, leaving a legal gap for AI-generated works.

Employer-Employee and Commissioned Works

Indian copyright law does recognize situations where the author is not the copyright holder. Section 17 of the Act specifies that in the case of works created by an employee during the course of their employment, the employer is deemed the first owner of the copyright, unless there is an agreement to the contrary.⁵ This also applies to works commissioned for valuable consideration. These provisions could be extended by analogy to AI-created works, where the human operator or the entity developing or commissioning the AI may be considered the copyright holder, despite not being the direct creator of the work.

The Need for Legal Reform

The Copyright Act, 1957, in its current form, does not adequately address the challenges posed by AI-generated works. As India's creative and technological sectors increasingly adopt AI, it is essential for lawmakers to introduce provisions clarifying the ownership of such works. This may involve either attributing copyright to the developers or users of AI systems or establishing a new framework for recognizing machine-generated creations. The lack of clear guidelines presents a challenge for stakeholders, who must navigate a legal landscape designed for human creators in an era of AI-driven innovation.

AI As An Author: Can Machines Own Copyright?

The question of whether Artificial Intelligence (AI) can be recognized as an author in copyright law presents a significant legal and philosophical dilemma. Traditionally, copyright law, including India's Copyright Act, 1957, centers on the concept of human authorship. Section 2(d) of the Act defines an "author" as a human creator responsible for a work's originality.[6] However, as AI-generated works become more prevalent, such as music, literature, and visual art, the notion of authorship has come into question. This raises an important issue: can machines, which lack human consciousness or intent, be recognized as authors under Indian copyright law?

The Human-Centric Focus of Indian Copyright Law

Under current Indian law, copyright protection is granted to works created by humans. To qualify for copyright, a work must exhibit originality, meaning it should originate from the creator and demonstrate a degree of skill, judgment, or creativity.[7] Works generated entirely by AI lack the element of human creativity and intention, which forms the foundation of copyright law. This creates a legal gap for works where AI plays the central role in creation.

The absence of any explicit provisions in the Copyright Act, 1957 addressing AI-generated works means that, as of now, copyright protection cannot be extended directly to machines. Courts in India have not yet adjudicated on this issue, but it is likely that the judiciary would follow established legal principles that prioritize human authorship. The current legal framework implies that works produced without human intervention cannot qualify for copyright protection.[8]

International Approaches to AI Authorship

Globally, there are differing approaches to the question of AI as an author. The United States and the European Union maintain a strict stance, where human authorship is a requirement for copyright protection. The U.S. Copyright Office has consistently rejected copyright claims for AI-generated works, citing the absence of human involvement.[9] The European Union's Copyright Directive (2019) similarly underscores the necessity of human creation in its provisions, leaving no room for machine authorship.[10]

In contrast, the United Kingdom offers a more flexible approach. The Copyright, Designs and Patents Act, 1988 provides that in the case of computer-generated works, the person who "makes the arrangements necessary" for the creation of the work is deemed the author.[11]This provision, while still involving human input, recognizes the increasing role of machines in the creative process. Such an approach offers a possible pathway for reform in India's copyright regime, should lawmakers choose to adapt to AI-driven innovation.

Should AI Be Considered an Author?

The question of AI as an author extends beyond legal interpretation and into philosophical and ethical considerations. AI lacks the attributes typically associated with authorship, such as intention, consciousness, and creativity in the human sense. Machines are programmed to learn patterns and generate outputs based on pre-existing data, but they do not possess independent thought or creative will.[12]These factors suggest that AI is more of a tool than a creator, making it difficult to justify the attribution of copyright ownership to a machine.

Attributing copyright to AI could also create practical and legal complications. For instance, if an AI system holds copyright, who would enforce it? Machines do not have legal personality, and granting them ownership rights would require a significant rethinking of legal principles. In such cases, the copyright could instead be attributed to the human operator, programmer, or the entity that owns or develops the AI system.

Possible Solutions for AI-Created Works in India

One possible solution within the Indian context is to follow the UK's model, attributing copyright to the person or entity responsible for making the arrangements necessary for the AI to create the work. This could involve developers, programmers, or even companies that fund the development of AI systems. Alternatively, India could develop a new licensing system specifically for AI-generated works, allowing creators to retain some rights over the output while recognizing the unique nature of machine-generated creativity.

Given the rapid evolution of AI and its increasing role in creative industries, Indian lawmakers will need to address these issues through legislative reform. This will ensure that both human creativity and AI innovation are adequately protected within the framework of copyright law.

International Approaches And Their Influence On Indian Law

The question of how to address copyright in works generated by Artificial Intelligence (AI) has provoked diverse responses across legal systems worldwide. With AI playing an increasingly prominent role in generating creative works, countries have adopted varying approaches to determine who, if anyone, holds copyright for such works. India's existing copyright framework, rooted in the Copyright Act, 1957, currently does not address these complexities. However, global trends offer valuable insights into potential pathways India could adopt to regulate AI-generated works.

The United States Approach: A Strict Human Authorship Requirement

The United States maintains a strict interpretation of copyright law, requiring human authorship for protection. The U.S. Copyright Office, through its Compendium of U.S. Copyright Office Practices, has consistently held that works lacking human authorship, including AI-generated works, are not eligible for copyright.[13] For example, the U.S. Copyright Office refused to grant copyright to a work created entirely by an AI program called "Creativity Machine," emphasizing the need for human creativity.[14] The rationale is that copyright law seeks to promote creativity and originality, which are attributes that AI lacks since it operates based on programmed algorithms without personal intention or consciousness.

This strict stance emphasizes the importance of human creativity as the cornerstone of copyright law. Given that Indian copyright law shares similar foundational principles of human authorship and originality, the U.S. approach could inform India's legal interpretation of copyright for AI-generated works. Indian courts may follow the U.S. precedent in maintaining a requirement for human authorship, at least until legislative reforms are introduced.

The European Union: Copyright Directive and AI

The European Union (EU) also prioritizes human creativity in copyright law. The EU Directive 2019/790 on Copyright and Related Rights in the Digital Single Market highlights the need for human intervention in creative processes to claim copyright.[15] The directive primarily focuses on ensuring the protection of creators, particularly in the context of digital platforms, but has not yet addressed the role of AI-generated works in detail. However, the emphasis on human creativity suggests that AI-generated works, devoid of human intervention, would not be eligible for copyright protection within the EU.

The EU's focus on human authorship is in line with the principles of the Berne Convention for the Protection of Literary and Artistic Works, to which India is also a signatory.[16] This international treaty, which forms the basis of copyright law in many jurisdictions, underscores the protection of works authored by humans. The alignment between the EU's legal principles and India's international obligations under the Berne Convention may lead India to adopt a similar position, resisting the extension of copyright to AI-generated works without human involvement.

The United Kingdom: A More Flexible Approach

The United Kingdom offers one of the more flexible legal frameworks regarding AI-generated works. The Copyright, Designs and Patents Act, 1988 (UK) includes provisions for "computer-generated works," defined as works generated by a computer in circumstances where there is no human author. Under this regime, the person who makes the arrangements necessary for the creation of the work is deemed to be the author.[17] This approach provides a solution for recognizing the contributions of individuals or entities that utilize AI to generate creative works, even if they do not directly create the content themselves.

India could draw inspiration from the UK model by attributing copyright to the person or entity responsible for making the arrangements necessary for the AI-generated work, such as the developers or programmers behind the AI system. This approach would recognize the importance of human input in the AI creation process without needing to extend copyright to the AI itself.

Influence on Indian Law

India's copyright law does not yet explicitly address AI-generated works. However, as the country increasingly adopts AI across various sectors, the legal questions surrounding authorship and copyright for AI-generated content are becoming more pressing. Global trends, particularly the U.S. and EU's emphasis on human authorship and the UK's more flexible approach, could influence future Indian legislative reforms.

Indian courts, traditionally influenced by common law jurisdictions like the UK, may find the UK's approach to computer-generated works appealing. At the same time, India's participation in international treaties like the Berne Convention may encourage it to align with the human-centric focus of the U.S. and EU copyright frameworks. Scholars like Dr. Arul George Scaria have argued for a balanced approach, suggesting that India should consider providing limited copyright protection for AI-generated works while ensuring human creators remain central to copyright law.[18]

In conclusion, while India has yet to formulate a clear legal stance on AI-generated works, the international experience provides a range of models that India could adapt. Legislative reform in India will likely balance the need to protect human creativity with the growing influence of AI in content creation.

The Role Of The Human In Ai-Created Works

The role of humans in AI-generated works is a pivotal issue in copyright law. AI systems, while capable of producing creative outputs, do so based on algorithms and pre-programmed data sets, lacking the human traits of intention, creativity, and originality. In this context, the human involvement behind AI—whether as a developer, operator, or user—becomes crucial in determining copyright ownership.

Under India's Copyright Act, 1957, authorship is traditionally defined around human creativity, requiring an element of personal intellectual effort.[19] However, AI-generated works challenge this framework, as the human's role may vary from minimal input to detailed programming and data selection. Dr. Arul George Scaria argues that, in such cases, the human responsible for setting the parameters or programming the AI could be seen as the "author" under the law, given their role in guiding the machine's output.[20]

Internationally, approaches vary. The UK's Copyright, Designs and Patents Act, 1988 assigns authorship to the individual who made the necessary arrangements for the creation of a computer-generated work.[21] This recognizes that, while the AI might create the work, the human's role in setting up the system is essential. Similarly, David McGowan highlights that AI can be viewed as a tool, like a camera or typewriter, where the person controlling or programming the AI retains authorship.[22]

Thus, the human's role in AI-generated works is often analogous to that of a director or facilitator. Whether by programming the AI or choosing its data inputs, human involvement is critical in shaping the final creative product, and by extension, determining who should hold copyright.

Relevant Case Laws On Ai And Copyright:
While the question of AI-generated works and copyright is relatively new, there are some key cases both Indian and international that provide guidance on the evolving legal landscape. These cases focus on authorship, originality, and the human role in the creation process, all of which are central to determining copyright ownership in AI-generated works.

1. Feist Publications, Inc. v. Rural Telephone Service Co. (1991, U.S.):
   In Feist Publications, Inc. v. Rural Telephone Service Co., the U.S. Supreme Court clarified that copyright requires a minimal degree of creativity and cannot merely protect facts or data.[23]In this case, a telephone directory was deemed uncopyrightable due to its lack of originality. This principle applies to AI-generated works because AI often relies on data sets and existing information to generate outputs. Therefore, if an AI simply reproduces or rearranges data without significant creative input from a human, the work may not qualify for copyright protection. This case highlights the importance of human creativity in generating original works, a principle that is central to most copyright regimes, including India's.
    
2. Naruto v. Slater (2018, U.S.):
   In Naruto v. Slater, a monkey named Naruto took a selfie using a camera set up by a photographer. The People for the Ethical Treatment of Animals (PETA) filed a lawsuit claiming that the monkey should own the copyright to the image. The U.S. Court of Appeals for the Ninth Circuit rejected the claim, ruling that animals cannot own copyright.[24] While this case did not involve AI, it is relevant to the AI copyright debate because it established that non-human entities (whether animals or machines) cannot be granted copyright under current legal frameworks. This aligns with the traditional requirement of human authorship and is indicative of how courts may treat AI-generated works in the future.
    
3. In Re: Thaler Application (2022, U.K.):
   In the Thaler Application case, Dr. Stephen Thaler filed patent applications in the UK, U.S., and Australia, naming his AI system, DABUS, as the inventor. While the case primarily focused on patents rather than copyright, the UK Intellectual Property Office and courts denied the application on the grounds that the inventor must be a human.[25] This ruling is significant because it underscores the current legal consensus that machines cannot be considered authors or inventors, reinforcing the human-centric nature of intellectual property law. In terms of copyright, this case suggests that works generated by AI would not be eligible for copyright protection unless a human can be identified as the author.
    
4. Eastern Book Company v. D.B. Modak (2008, India):
   In Eastern Book Company v. D.B. Modak, the Supreme Court of India addressed the concept of originality in copyright law. The case involved a dispute over the copyrightability of judicial decisions published in a law reporter. The court held that copyright requires a degree of creativity, ruling that merely selecting and arranging pre-existing materials, such as legal judgments, did not meet the originality requirement.[26] This ruling is relevant in the context of AI-generated works because AI often creates works by selecting, arranging, or transforming existing data. Without human creative input, such works may not meet the originality standard required for copyright in India.

Policy Recommendations For India
As India navigates the complexities of AI-generated works and copyright law, several policy recommendations could help address the emerging challenges and ensure that the legal framework supports both innovation and creators.

1. Define AI-Created Works: India should consider amending the Copyright Act, 1957 to include explicit provisions for AI-generated works. This could involve defining "computer-generated works" similarly to the UK's approach, where copyright is attributed to the person who made the arrangements necessary for the creation of the work.^[27] This would provide clarity on ownership and protect the interests of developers and users of AI systems.
    
2. Recognize Human Involvement: Acknowledge the crucial role of human involvement in the creative process by introducing a provision that attributes copyright to the human or entity responsible for programming, operating, or commissioning the AI. This approach aligns with international practices and addresses the practical need for a clear copyright holder in the absence of human authorship.^[28] David McGowan and Dr. Arul George Scarias suggest that recognizing the human operator or developer as the copyright holder would ensure that rights are appropriately assigned while maintaining the integrity of human creativity.^[29]
    
3. Foster Innovation through Licensing: Develop a specific licensing framework for AI-generated works that allows creators to retain some rights while accommodating the unique nature of machine-generated content. This could include a system for registering AI-generated works and establishing terms of use that reflect the contributions of both the AI and its human handlers. Such a framework could incentivize innovation and ensure fair compensation for all parties involved.
    
4. Monitor and Adapt to Technological Advancements: Establish a regulatory body to monitor technological developments and assess the impact of AI on copyright law regularly. This body could provide recommendations for periodic updates to the legal framework, ensuring that Indian copyright law remains relevant in the face of rapid technological advancements. This proactive approach would help India stay aligned with global standards and best practices.^[30]

Implementing these recommendations would help India create a balanced and forward-looking copyright regime that addresses the challenges posed by AI while fostering innovation and protecting creators' rights.

Conclusion
The rise of Artificial Intelligence (AI) has ushered in a new era of creativity, where machines are increasingly capable of generating works that were once the exclusive domain of human authors. This technological advancement presents a significant challenge for traditional copyright frameworks, including India's Copyright Act, 1957. As AI systems produce works ranging from music and art to literature, the question of copyright ownership becomes both complex and critical.

India's current copyright law is grounded in the principle of human authorship, requiring that works be created by individuals to qualify for protection. This framework has served well in the past but is ill-equipped to address the nuances of AI-generated content. AI systems, driven by algorithms and vast datasets, operate without personal creativity or intent, which are cornerstones of traditional copyright law. As a result, the existing legal structure fails to accommodate the unique nature of machine-generated works, leaving a significant gap in intellectual property protection.

International approaches offer valuable insights into potential pathways for India. For instance, the U.S. Copyright Office has firmly maintained that copyright requires human authorship, excluding AI-generated works from protection. This perspective underscores the importance of human creativity and sets a high bar for recognizing authorship. Conversely, the UK's Copyright, Designs and Patents Act, 1988 provides a more flexible model by attributing copyright to the person who makes the arrangements necessary for a computer-generated work, acknowledging the role of human input in AI-driven creations. Similarly, international cases like Naruto v. Slater and In Re: Thaler Application reinforce the current legal consensus that non-human entities, including AI, cannot hold copyright, highlighting the need for a human element in copyright claims.

In light of these considerations, several policy recommendations can help India navigate this evolving landscape. First, amending the Copyright Act to explicitly address AI-generated works is crucial. This could involve defining "computer-generated works" and attributing copyright to the individual or entity responsible for the AI's development or operation. Such a provision would provide clarity and ensure that those who contribute to the creative process, even indirectly, are recognized and protected.

Second, acknowledging the role of human involvement is essential. Recognizing that AI is a tool operated and programmed by humans allows for a pragmatic approach where copyright is attributed to those who make significant contributions to the creation of the work. This approach aligns with global practices and addresses the practical realities of AI-generated content.

Third, developing a specific licensing framework for AI-generated works can facilitate fair compensation and incentivize innovation. This framework should account for the unique nature of AI-created content while ensuring that creators, developers, and users have clear guidelines for rights and responsibilities.

Finally, establishing a regulatory body to monitor technological advancements and adapt copyright law accordingly would ensure that India's legal framework remains relevant and responsive. This body could provide ongoing assessments and recommendations, helping India stay aligned with global standards and address emerging challenges effectively.

In conclusion, addressing copyright for AI-generated works is a complex but necessary task. By drawing on international practices and adapting its legal framework, India can create a balanced approach that supports innovation, protects creators' rights, and navigates the intersection of technology and intellectual property. As AI continues to advance, proactive and thoughtful reforms will be essential in ensuring that copyright law evolves to meet the needs of a rapidly changing creative landscape.

End Notes:

• Books:
  • Arul George Scaria, Does India Need a New Copyright Regime for AI-Generated Works? Journal of Intellectual Property Rights, vol. 23, no. 5, 2018, pp. 227-235.
  • David McGowan, Artificial Intelligence and Copyright Law, 83 North Carolina Law Review, 2004.
  • J. H. Reichman, The Public Domain in a Digital Environment, Journal of the Copyright Society of the U.S.A., vol. 52, 2005, pp. 509-556.
  • Russell, Stuart J., and Peter Norvig, Artificial Intelligence: A Modern Approach, Pearson, 2010.
• Research Articles:
  • David McGowan, "Artificial Intelligence and Copyright Law," 83 North Carolina Law Review 1 (2004).
  • Arul George Scaria, "Does India Need a New Copyright Regime for AI-Generated Works?" Journal of Intellectual Property Rights 23, no. 5 (2018): 227-235.
  • J. H. Reichman, "The Public Domain in a Digital Environment," 52 Journal of the Copyright Society of the U.S.A. 509 (2005).
  • Feist Publications, Inc. v. Rural Telephone Service Co., 499 U.S. 340 (1991).
  • Naruto v. Slater, 888 F.3d 418 (9th Cir. 2018).
  • In Re: Thaler Application, [2022] EWHC 2412 (Pat).
  • Eastern Book Company v. D.B. Modak, AIR 2008 SC 809.
• Reports:
  • U.S. Copyright Office, Compendium of U.S. Copyright Office Practices, 3rd ed., 2017.
  • European Parliament and Council, Directive 2019/790 on Copyright and Related Rights in the Digital Single Market, 2019.
  • Copyright, Designs and Patents Act 1988, c. 48, UK.
• End Notes:
  1. Copyright Act, 1957, sec 2(d).
  2. Copyright Act, 1957.
  3. Copyright Act, 1957.
  4. Copyright Act, 1957.
  5. Copyright, Designs, and Patents Act 1988, c. 48, 9(3) (UK).
  6. Copyright Act, 1957, sec 2(d).
  7. Copyright Act, 1957, sec 13.
  8. Copyright Act, 1957, sec 2(d).
  9. U.S. Copyright Office, Compendium of U.S. Copyright Office Practices, sec 313.2 (3d ed. 2017).
  10. European Parliament and Council Directive 2019/790/EU, on Copyright and Related Rights in the Digital Single Market.
  11. Copyright, Designs and Patents Act 1988, c. 48, sec 9(3) (UK).
  12. Russell, Stuart J., and Peter Norvig. Artificial Intelligence: A Modern Approach. Pearson, 2010.
  13. U.S. Copyright Office, Compendium of U.S. Copyright Office Practices, sec 313.2 (3d ed. 2017).
  14. David McGowan, "Artificial Intelligence and Copyright Law," 83 North Carolina Law Review 1 (2004).
  15. European Parliament and Council Directive 2019/790/EU, on Copyright and Related Rights in the Digital Single Market, art. 2.
  16. Berne Convention for the Protection of Literary and Artistic Works, 1886.
  17. Copyright, Designs and Patents Act 1988, c. 48, sec 9(3) (UK).
  18. Arul George Scaria, "Does India Need a New Copyright Regime for AI-Generated Works?" Journal of Intellectual Property Rights 23, no. 5 (2018): 227-235.
  19. Copyright Act, 1957, § 2(d).
  20. Arul George Scaria, "Does India Need a New Copyright Regime for AI-Generated Works?" Journal of Intellectual Property Rights 23, no. 5 (2018): 227-235.
  21. Copyright, Designs and Patents Act 1988, c. 48, 9(3) (UK).
  22. David McGowan, "Artificial Intelligence and Copyright Law," 83 North Carolina Law Review 1 (2004).
  23. Feist Publications, Inc. v. Rural Telephone Service Co., 499 U.S. 340 (1991).
  24. Naruto v. Slater, 888 F.3d 418 (9th Cir. 2018).
  25. In Re: Thaler Application, [2022] EWHC 2412 (Pat).
  26. Eastern Book Company v. D.B. Modak, AIR 2008 SC 809.
  27. Copyright, Designs and Patents Act 1988, c. 48, 9(3) (UK).
  28. David McGowan, "Artificial Intelligence and Copyright Law," 83 North Carolina Law Review 1 (2004).
  29. Arul George Scaria, "Does India Need a New Copyright Regime for AI-Generated Works?" Journal of Intellectual Property Rights 23, no. 5 (2018): 227-235.
  30. J. H. Reichman "The Public Domain in a Digital Environment," 52 Journal of the Copyright Society of the U.S.A. 509 (2005).