Aligning AI Regulatory Approaches: Multi- Layered Frameworks and Social Justice in the EU, US, and India

Abstract

The review article examines the comparative governance of artificial intelligence (AI) in the European Union, the United States, and India, focusing on various issues such as liability, bias, privacy, and AI use in judicial processes, while attending to legal, ethical, and social justice considerations. There are distinct regulatory strategies for the working of AI systems. in each jurisdiction. The EU has introduced a comprehensive AI Act with a risk- based, rights-oriented regime. The United States relies on a decentralized, agency-led model grounded in sectoral oversight and standards. India, is still formulating AI governance guidelines that emphasizes on the areas of  innovation and inclusion. Despite these divergent frameworks, common concerns emerge around ensuring algorithmic accountability, protection of  privacy and individual rights, preserving public trust, and preventing any discriminatory outcomes. Based on these outcomes, the paper proposes a novel multi-layered regulatory framework that deals with the integration of statutory regulation, ethical guidelines, and oversight mechanisms across different levels of governance. This approach harmonizes substantive aspect with practicality, balances innovation with accountability, and embeds ethical and social justice principles into AI regulation. By bridging these dimensions, the framework aims to ensure robust framework on liability, mitigation of bias efficiently, protection of data privacy, and responsible use of AI  in judicial arena. The comparative analysis emphasize the need for cohesive AI governance that adapts to different legal systems along with the  upholding common principles of justice and accountability.