As Artificial Intelligence (AI) continues to play an increasingly prominent role in (music, art, games, and films) creative industries, questions arising copyright protection for AI-generated works have emerged globally. This paper offers a comparative analysis of how India, Australia and US differently address the use of AI Generated Content in copyright law. The role of AI in creativity and innovation has been recognized worldwide. In India, the Copyright Act of 1957, which emphasizes human authorship, does not specifically account for works generated by AI. The Indian Copyright Act, 1957 is the primary law that governs copyright in India. The Act has undergone several amendments over time, with the most significant amendments being made in 1983, 1994, 1999, and 2012 to address emerging issues, including those related to digital technologies. Indian government has taken several steps to reduce the confusion about AI on copyright. In contrast, Australia’s Copyright Act of 1968 follows a similar framework, recognizing human authorship as central to copyright ownership. However, the Australian Copyright Act of 1968 is the primary legislation governing copyright law in Australia. It outlines the rights of authors and creators over their original works and specifies how these works are protected. With ongoing discussions regarding legal reforms that may better address the challenges posed by AI technologies in creative processes. Australian legal scholars and policymakers are increasingly considering whether the current copyright structure adequately accommodates the rise of AI-driven works. In the US, the Copyright Act, 1976 does not protect the works generated independently by the AI without human intervention and thus dropping such works in the public domain immediately after their creation. In conclusion, in comparing the copyright laws of India, Australia and US in relation to Artificial Intelligence (AI), it becomes evident that while all countries face similar challenges, their approaches to addressing AI-generated works remain underdeveloped and inconsistent with emerging technological advancements. Furthermore, the paper considers the stance of the US, Australian and India protecting AI generated works to suggest measures to the current copyright regime in India.
Ojha et al. (Mon,) studied this question.
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