AI-Generated Fake Judgments Under Fire As Supreme Court & Bombay HC Warn Lawyers
· Free Press Journal
Mumbai: Courts in India and abroad are beginning to confront a troubling pattern: lawyers submitting case law that turns out to be entirely fictitious and generated by artificial intelligence tools such as ChatGPT.
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The Supreme Court of India has already dealt with this problem directly. In Gummadi Usha Rani v. Sure Mallikarjuna Rao (2025), the Court discovered that the trial court had relied on four “judgments” that did not exist in any official law report. The Supreme Court made the following scathing observations:
“We take cognisance of the Trial Court deploying AI generated non-existing, fake or synthetic alleged judgments and seek to examine its consequences and accountability as it has a direct bearing on integrity of adjudicatory process. At the outset, we must declare that a decision based on such non-existent and fake alleged judgments is not an error in the decision making. It would be a misconduct and legal consequence shall follow.”
The warning was repeated months later when another Bench, while hearing a matter involving fabricated citations, observed that the spread of AIgenerated case law had become a “menace” and that courts were routinely encountering submissions containing judgments that no digital or physical law library could trace.
High Courts have faced similar situations. The Bombay High Court, in Mr. Deepak s/o Shivkumar Bahry Versus Heart & Soul Entertainment Ltd., recently flagged a written submission citing a case titled Jyoti w/o Dinesh Tulsiani v. Elegant Associates. The Court’s registry confirmed that no such judgment had ever been delivered. The judge noted that valuable judicial time had been wasted verifying material that should never have been filed.
The court observed: “If an AI tool is used in aid of research, it is welcome; however, there is great responsibility upon the party, even an advocate using such tools, to cross verify the references and make sure that the material generated by the machine/computer is really relevant, genuine and in existence.”
In another recent case, the Bombay High Court imposed costs of `50,000 on a litigant for submitting a “non-existing” judgment generated through artificial intelligence, which neither the Court nor its clerks could locate. The Court deprecated the practice of dumping non-existent and irrelevant material before it.
These cases signal a turning point for the legal profession. Courts are making it clear that while AI may accelerate legal research, it cannot replace the discipline, caution and ethical responsibility that define advocacy. The message is unmistakable: technology may assist, but it cannot absolve lawyers of their professional responsibility.
(The writer is a HC advocate)
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