Madras High Court orders FIR and freezes accounts over alleged AI-generated library books

The Madurai Bench told the vigilance directorate to register an FIR over books bought for Tamil Nadu public libraries. Rule 18(4) of the Libraries Rules, Article 14 in procurement, anti-corruption provisions and copyright in machine output explained.

The Madurai Bench of the Madras High Court has ordered the Directorate of Vigilance and Anti-Corruption (DVAC) to register an FIR over the purchase of fake and allegedly AI-generated books for Tamil Nadu public libraries, and to freeze the bank accounts of the publisher at the centre of the row.

A bench of Justices G.R. Swaminathan and M.D. Sumathi passed the order on 10 November 2026 in a contempt petition about the court's own earlier directions on book procurement.

The accounts of Agal Vilakku Publications, its proprietor and others allegedly involved are to be frozen. On 11 November the State told the bench that DVAC would register a structured FIR within four days, and the matter returns on Monday, 16 November 2026.

What the court ordered

The petition, V. Ramasubbu v. Dr K. Gopal and another, alleges that the State did not follow a judgment of 19 June 2024 requiring transparent procurement of library books. The bench told the DVAC to register an FIR against unknown public servants and told the government to take immediate disciplinary action, including suspension of the officials involved.

The Director of Public Libraries must give the names of the officials responsible for procurement over the last two years, so that they can be added as contemnors.

Librarians must prepare an inventory of the questioned books and keep them from readers, and the Director must disclose the amount spent and file an affidavit setting out the full sequence of events.

The court said a crime of this scale could not have taken place without the active involvement of government servants. Justice Swaminathan called the non-compliance blatant disobedience and said "heads must roll".

How the row began

The controversy broke after the Tamil writer Perumal Murugan wrote about what he called a colossal fraud in the books bought for the Periyar Arivulagam library in Coimbatore, on the eve of Deepavali.

A book attributed to the economist Jean Drèze that was displayed at the Kalaignar Centenary Library in Madurai was denounced by him as fake, and works falsely attributed to the poet Subramania Bharathi were found on shelves.

The court noted that no FIR had been registered for about a week after the facts surfaced. The School Education Department complained to DVAC on 6 November, and DVAC began an inquiry on 7 November.

The 2024 judgment arose from a 2019 writ petition by S. Krishnan of Nagercoil about books bought under changed titles and author names.

It laid down a Transparent Book Procurement Policy: a procurement website, notice to Tamil Nadu publishers with at least 200 books, publication of shortlisted titles and covers with a month for objections, and an inquiry committee that was to report within five months.

The 11 November hearing

State Public Prosecutor John Sathyan told the bench that DVAC questioned the publisher on 9 November and examined four witnesses on 10 November, including Perumal Murugan. Three bank accounts holding about Rs 22.2 lakh have been frozen.

The Director of Public Libraries said that 1,700 of 2,237 recommended titles, one copy each, were bought from Agal Vilakku for Periyar Arivulagam at about Rs 17 lakh. The publisher Badri Seshadri, assisting the court, called the figure obscenely high and said the titles must have been inserted somewhere in the list.

Justice Swaminathan noted that the expert committee had recommended the Tamil translation of the Prime Minister's radio addresses, Mann Ki Baat, but it was not bought, while Agal Vilakku titles were.

He said the State had not identified a single erring official, and the Director was told to file an affidavit by Monday with procurement data from publishers over recent years. As he put it, "The story is not over."

Do AI-generated books fall foul of the rules

The bench read rule 18(4) of the Tamil Nadu Public Libraries Rules, 1950, which bars books of doubtful taste, broadly. It held that dubious content and false narratives are covered and that "AI-generated and plagiarised works also would fall within this ambit".

A library may not buy such a book unless the selection committee is satisfied that it meets the standard. The court said selection committees must assess books by first-time authors, and extended that to non-fiction.

The State's counsel described the books in court as AI-generated. The reports of the hearings do not say how many titles are machine-written or how that was established, and the bench has made no reported finding on the point.

Public procurement and Article 14

A government purchase must meet Article 14. M.P. Jain writes in Indian Constitutional Law that under Ramana Dayaram Shetty v. International Airport Authority (1979) 3 SCC 489 the government has no unrestricted choice of whom to deal with, must follow rational and non-discriminatory standards, and is bound by the standards it sets.

Tata Cellular v. Union of India (1994) 6 SCC 651 repeated that Article 14 governs the acceptance or refusal of a tender. Jain adds that the Supreme Court has treated the award of a government contract without inviting tenders as an invalid pick-and-choose, which is the kind of discretion the 2024 judgment tried to bring into public view.

Criminal and anti-corruption provisions

The bench referred to the Bharatiya Nyaya Sanhita and the Prevention of Corruption Act, 1988, without any section being reported. Cheating is punished under section 318 of the Sanhita, criminal breach of trust by a public servant under section 316, and criminal conspiracy under section 61.

Under the 1988 Act, a public servant who dishonestly misappropriates property under his control commits criminal misconduct under section 13(1)(a), punishable with four to ten years. Section 17A requires prior approval before an inquiry into an official decision, and the reports of the order do not say how that section was handled.

In an investigation, police freeze accounts using section 106 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which lets them seize property suspected to be linked to an offence. Section 107 adds a court-ordered route to attach and forfeit the proceeds of crime.

Copyright and authorship of machine output

The bench flagged old books repackaged under false titles and authors. It cited a 2013 title as a copy of Kalki's Sivakamiyin Sabatham, and named Thiru Vi Ka, A. Sa. Gnana Sambanthan and Na. Parthasarathy among the writers whose works were republished as recent titles.

Under section 22 of the Copyright Act, 1957, copyright in a published literary work lasts until 60 years after the author's death, after which the text may be republished.

An author's right to claim authorship under section 57 is separate, and the court observed that where copyright is nationalised the government acts as custodian and must protect the right of the author to be identified.

For machine output, section 2(d)(vi) names as author of a computer-generated literary work the person who causes the work to be created. Parliament has not made it a separate category, and whether a work with no human author is original enough for copyright is not settled by the Act.

The Tamil Nadu libraries law

The court said bogus books and phantom authors breach the Tamil Nadu Public Libraries Act, 1948 and the right to accurate information under Article 19(1)(a). Secretary, Ministry of Information and Broadcasting v. Cricket Association of Bengal (1995) 2 SCC 161 had earlier recognised the freedom to receive information as part of free speech.

The Director of Public Libraries has until Monday, 16 November 2026 to file the affidavit, and DVAC's FIR is due to be reported to the bench on the same date.