Comparative Perspectives of Legal Personhood for Artificial Intelligence Systems: Takeaways from India, USA, and EU

The development of artificial intelligence (AI) has spurred difficult legal discussions over the possible recognition of AI systems as legal persons, a status usually reserved for natural persons and juridical entities such as corporations. This article examines the changing legal frameworks and philosophical underpinnings of AI legal personhood across three jurisdictions - India, the United States, and the European Union. Through comparative doctrinal analysis, it examines how each jurisdiction addresses core questions of AI rights, obligations, and legal standing. The study finds that none of the three jurisdictions has granted, or is close to granting, legal personhood to an AI system. The United States has resolved the narrow question of AI inventorship against personhood in Thaler v Vidal; the European Union proposed and then substantially retreated from the idea of “electronic personhood” between 2017 and the adoption of its AI Act in 2024; and India has so far addressed AI harms through existing doctrines of human accountability rather than through new legislation on AI status. The paper argues that the more useful comparative lesson is not how close each jurisdiction has come to AI personhood, but how consistently each has preferred to solve AI liability without it, and what that convergence suggests about the limits of the personhood debate as a policy tool.